Justia Tennessee Supreme Court Opinion Summaries

Charles Kilburn was injured in a motor vehicle accident and underwent surgery to resolve his neck injury complaints. Charles took oxycodone to alleviate his back pain. Several months after his surgery, Charles died due to an overdose of oxycodone combined with alcohol. The chancery court found that the death was compensable and awarded workers’ compensation death benefits to Judy Kilburn, Charles’s wife. The Supreme Court reversed the judgment of the chancery court, holding that Charles’s failure to take his medication in accordance with his doctor’s instructions ultimately caused his demise, and therefore, his death was no longer causally related to his work-related injury, and his overdose was an independent intervening cause. View "Kilburn v. Granite State Insurance Co." on Justia Law

When homeowners’ partially completed house and its contents were destroyed by fire, the homeowners sued the general contractor and the flooring subcontractors for damages, alleging that the fire was caused by the negligence of the general contractor and the subcontractors and that the general contractor had breached the construction contract. The trial court granted summary judgment to the general contractor and to the subcontractors. The court of appeals (1) affirmed summary judgment to the general contractor based on the inapplicability of res ipsa loquitur to establish an inference of negligence; and (2) reversed summary judgment to the subcontractors on the negligence claim and to the general contractor on the breach of contract claim, concluding that there remained genuine issues of disputed material fact. The Supreme Court affirmed in part and reversed in part the decision of the court of appeals and affirmed the trial court’s grant of summary judgment, holding (1) Plaintiffs could not rely on res ipsa loquitur because of insufficient proof that the general contractor had exclusive control of the cause or all reasonably probable causes of the fire; and (2) Plaintiffs did not produce sufficient evidence to establish that any negligence of the subcontractors was the cause in fact of the fire. View "Jenkins v. Big City Remodeling" on Justia Law

In this case, the Supreme Court overruled State v. Jacumin, in which the Court rejected a totality-of-the circumstances analysis for determining whether an affidavit establishes probable cause and instead adopted another test derived from two earlier United States Supreme Court decisions. Defendant here was charged with multiple offenses in connection with a drug trafficking conspiracy. Defendant moved to suppress evidence seized during a search, arguing that the affidavit supporting the search warrant failed to establish probable cause. The trial court denied the motion. Defendant was then found guilty of six offenses. The Court of Criminal Appeals reversed the trial court’s ruling on Defendant’s motion to suppress. The Supreme Court reversed the intermediate appellate court’s decision holding that the search warrant was invalid, holding (1) henceforth, a totality-of-the-circumstances analysis applies for determining whether an affidavit establishes probable cause for issuance of a warrant, and applying this standard, the search warrant in this case sufficiently established probable cause; (2) the Court of Criminal Appeals erred in concluding that the evidence was insufficient to support two of Defendant’s convictions; and (3) the Court of Criminal Appeals did not err in upholding that trial court’s judgment ordering forfeiture of the $1,098,050 cash seized when the search warrant was executed. View "State v. Tuttle" on Justia Law

Plaintiffs Stephen Michael West and Derrick D. Schofield were each convicted of first degree murder and sentenced to death. Plaintiffs bought a declaratory judgment action seeking a declaration that the written protocol by which the Tennessee Department of Correction carries out an execution by lethal injection violates the United States and Tennessee Constitutions. The trial court denied relief to Plaintiffs. The Supreme Court affirmed, holding that the trial court did not err in (1) concluding that Plaintiffs failed to carry their burden of demonstrating that the protocol, on its face, violates the constitutional prohibitions against cruel and unusual punishment; and (2) dismissing Plaintiffs’ claims that the protocol requires violations of federal drug laws. View "West v. Schofield" on Justia Law

Plaintiff was the secretarial assistant of Circuit Judge Harold Wimberly when Judge Wimberly lost the contested general election to William Ailor. Ailor informed Plaintiff that he would not require her services after taking office. Plaintiff filed suit against the State and Ailor in his individual capacity, alleging tortious interference with her employment relationship. Plaintiff also filed a complaint in the Claims Commission. Defendants moved to dismiss the complaint, arguing that the statute providing that claims against the State based on the acts or omissions of state employees shall operate as a waiver of any cause of action which the claimant has against any state officer or employee. The trial court declined to dismiss Plaintiff’s claims against Ailor, concluding that Ailor was not acting as a state officer or employee when he made the administrative staffing decision. The court of appeals affirmed. The Supreme Court reversed, holding that because Plaintiff’s employment automatically ended when Judge Wimberly’s term ended and because she remained employed until the end of Judge Wimberly’s term, as a matter of law, Ailor did not tortiously interfere with Plaintiff’s employment relationship. View "Moore-Pennoyer v. State" on Justia Law

The trial court entered a divorce decree between Mother and Father that incorporated an agreed parenting plan that did not designate a primary residential parent. After the divorce, Father spent the majority of the residential parenting time with the parties’ child. Father later filed a petition asking the trial court to modify the parenting plan to permit him to move with the child to Arizona because he had secured a job in an area where he and the child would live near family. After a trial, the trial court concluded that Father did not have a “reasonable purpose” for the relocation under Tennessee’s parental relocation statute, Tenn. Code Ann. 36-6-108. The court then entered a modified parenting plan designating Mother as the primary residential parent. The court of appeals affirmed. The Supreme Court reversed, holding (1) Webster v. Webster is overruled insofar as it misconstrued the meaning of the term “reasonable purpose” as used in the parental relocation statute; and (2) under the natural and ordinary meaning of the term “reasonable purpose,” Father stated a reasonable purpose for relocating with the parties’ child to Arizona, and Mother did not establish a ground for denying Father permission to relocate with the child. Remanded. View "Aragon v. Aragon" on Justia Law

Employee asserted a private right of action against Employer under the Tennessee Tip Statute, Tenn. Code Ann. 50-2-107, for Employer’s failure properly to pay tips, gratuities, and service charges. The trial court granted Employer’s motion to dismiss for failure to state a claim on the ground that there was no private right of action under the statute. The court of appeals reversed based in part on a 1998 court of appeals opinion, Owens v. University Club of Memphis, recognizing a private cause of action under the Tip Statute. The Supreme Court reversed the judgment of the court of appeals and affirmed the trial court’s judgment, holding (1) Owens is inconsistent in part with subsequent Supreme Court jurisprudence on implying a private right of action under a statute, and therefore, this Court declines to apply the doctrine of legislative inaction to presume that the legislature knew of the holding in Owens and acquiesced in it; and (2) Owens is overruled to the extent that it is inconsistent with the Court’s holding here that an employee has no private right of action under section 50-2-107. View "Hardy v. Tournament Players Club at Southwind, Inc." on Justia Law

Rogelynn Emory, a full-time tenured teacher in the Memphis City School System, was terminated after the Memphis City Schools Board of Education concluded after a hearing that there was ample evidence of Emory’s unsatisfactory job performance. Emory subsequently filed a petition for judicial review. The trial court affirmed the Board’s decision. The Court of Appeals declined to reinstate Emory based on the untimeliness of the school board hearing but awarded her partial back pay. The Supreme Court affirmed the decision to upheld the termination of Emory’s employment and clarified the standard of judicial review for the termination of a tenured teacher under the Tenure Act, holding (1) the Court of Appeals’ award of partial back pay was without basis in the Teachers’ Tenure Act; and (2) because Emory failed to raise before the school board any objection as to the timeliness of her hearing, that issue was not properly before the Supreme Court. View "Emory v. Memphis City Schools Board of Education" on Justia Law

In 2009, Appellant pleaded guilty to attempted rape of a child. That same year, Appellant began serving his sentence. On March 26, 2013, a Tennessee Board of Parole hearing officer conducted a parole hearing for Appellant based on a release eligibility date of June 14, 2013. The hearing offer recommended that parole be denied. The Board concurred and deferred the next parole hearing until 2013. Appellant filed a petition of certiorari, asserting that the Board’s decision was illegal, contrary to established law, and arbitrary and capricious. The trial court dismissed the petition. Appellant appealed. The Court of Appeals did not consider the issues raised by Appellant but, instead, determined that Appellant’s release eligibility date was April 3, 2015. The Court of Appeals then remanded the case to the trial court with instructions for the Board to conduct an immediate parole hearing for Appellant. The Supreme Court reversed the Court of Appeals and affirmed the trial court’s decision, holding that the Court of Appeals lacked the authority to calculate the date Appellant could be considered for parole and did so incorrectly. View "Brennan v. Tennessee Board of Parole" on Justia Law

Defendant was indicted for, inter alia, two counts of first degree premeditated murder. The trial court denied Defendant’s motion to suppress evidence seized from his residence, ruling that the Exclusionary Rule Reform Act applied to the case despite ex post facto concerns. The jury then convicted Defendant as charged. The jury sentenced Defendant to life sentences without the possibility of parole for the murders. The court of criminal appeals upheld Defendant’s convictions and sentences. At issue before the Supreme Court was whether the Court should modify the Tennessee ex post facto analysis found in Miller v. State in light of Collins v. Youngblood. The Supreme Court affirmed on separate grounds, holding (1) Miller v. State is overruled; (2) the ex post facto clause of the Tennessee Constitution has the same definition and scope as the federal ex post facto clause; (3) the application of the Exclusionary Rule Reform Act to this case was not an ex post facto violation; (4) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a search warrant; and (5) Defendant was not entitled to relief on his remaining issues. View "State v. Pruitt" on Justia Law