Justia Tennessee Supreme Court Opinion Summaries

A Hospital brought this lawsuit against a TennCare managed care organization (MCO), alleging that the MCO had not paid the Hospital all it was due for emergency services provided to the MCO’s TennCare enrollees. The MCO counterclaimed, seeking recovery of alleged overpayments made pursuant to the TennCare regulations. Thereafter, the MCO filed a motion for partial summary judgment, arguing that the Uniform Administrative Procedures Act (UAPA) required the Hospital to exhaust its administrative remedies by bringing its claims before TennCare prior to filing suit. The trial court agreed and dismissed the Hospital’s complaint and the MCO’s counterclaim for lack of subject matter jurisdiction. The Supreme Court reversed, holding (1) the UAPA requires exhaustion of administrative remedies in this matter to the extent that resolution of the parties’ claims would require the trial court to render a declaratory judgment concerning the validity or applicability of TennCare regulations; but (2) while the UAPA prohibits the trial court from rendering such declaratory relief absent exhaustion of administrative remedies, it does not address claims for damages. Remanded to the trial court with directions to hold the parties’ damage claims in abeyance pending resolution of administrative proceedings regarding the validity or applicability of the TennCare regulations at issue. View "Chattanooga-Hamilton County Hosp. Auth. v. UnitedHealthcare Plan of the River Valley, Inc." on Justia Law

Five separate groups of Pennsylvania-domiciled insurance companies (collectively, “Claimants”) were authorized to provide workers’ compensation coverage in Tennessee. As a result of an audit conducted by the State of Tennessee, Claimants were required, under Tennessee’s retaliatory tax statute, to recalculate their Tennessee taxes to include certain Pennsylvania workers’ compensation charges, file amended tax returns, and remit payment of the additional taxes totaling over $16 million. Claimants paid the taxes under protest. Each Claimant subsequently filed a complaint with the Tennessee Claims Commission (the “Commissioner”) seeking a refund of the retaliatory taxes paid under protest. The Commissioner issued five identical judgments, each granting summary judgment in favor of the State. The Court of Appeals affirmed. The Supreme Court reversed, holding that because the Pennsylvania workers’ compensation assessments were no longer paid by the insurance companies but were imposed on the employer-policyholders in conjunction with their premium payments, the administrative task of collecting and remitting those payments did not qualify as a burden on the insurance companies for purposes of the retaliatory tax. View "Chartis Casualty Co. v. State" on Justia Law

Plaintiffs filed this action against Defendant, a licensed clinical social worker, alleging negligence, negligence per se, and intentional infliction of emotional distress for providing counseling services for their minor daughter without their consent. Defendant filed a motion to dismiss based on Plaintiffs’ failure to comply with the pre-suit notice and certificate of good faith requirements of the Tennessee Health Care Liability Act (“THCLA”). Plaintiffs responded that their claims were not subject to the THCLA’s procedural requirements because their claims sounded in ordinary negligence. The trial court dismissed all of Plaintiffs’ claims, concluding that the THCLA encompassed Plaintiffs’ claims because they related to the provision of “health care services” by a “health care provider.” The Court of Appeals vacated the trial court’s order and remanded, concluding that the trial court erred by failing to apply the Supreme Court’s analysis in determining if Plaintiffs’ claims sounded in ordinary negligence or health care liability. The Supreme Court reversed the Court of Appeals, holding (1) the Tennessee Civil Justice Act of 2011, which amended the THCLA, statutorily abrogated the Court’s decision in Estate of French; and (2) Plaintiff’s complaint was subject to the THCLA, which required them to provide pre-suit notice and a certificate of good faith. View "Ellithorpe v. Weismark" on Justia Law

Employee was terminated because of an altercation with an employee of a contractor at Employer’s wellness center. After his termination, Employee sought reconsideration of his three workers’ compensation claims. The trial court determined that Employee was entitled to reconsideration and awarded additional permanent disability benefits, concluding that Employer had not sustained its burden of proof that Employee’s misconduct was connected with his employment. The Supreme Court affirmed, holding (1) Employee was entitled to reconsideration of his previous award and settlements because the conduct that resulted in his termination was not connected with his employment; (2) the trial court’s erroneous evidentiary rulings constituted harmless error; and (3) the evidence did not preponderate against the trial court’s finding that Employee was entitled to additional permanent disability benefits. View "Stacey v. Nissan N.A., Inc." on Justia Law

In 2001, Father filed a petition to terminate Mother’s parental rights. Mother did not file an answer to the petition. The trial court subsequently entered a default judgment terminating Mother’s parental rights. In 2010, Mother filed a petition seeking to set aside the judgment terminating her parental rights as void for lack of personal jurisdiction. Father argued that Mother’s petition was barred by the one-year statute of repose applicable to judgments terminating parental rights and thus should be dismissed. The trial court granted Mother’s petition and set aside the default judgment terminating her parental rights. The Court of Appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the default judgment was void for lack of personal jurisdiction; (2) the reasonable time filing requirement of Tenn. R. Civ. P. 60.02 does not apply to petitions seeking relief from void judgments under Rule 60.02(3); and (3) however, relief from a void judgment should be denied if certain exceptional circumstances exist. Remanded for a hearing to determine whether exceptional circumstances justify denying relief in this case. View "Turner v. Turner" on Justia Law

Claimant filed a complaint against the City of Clarksville as a defendant. The circuit court granted the City’s motion to dismiss, concluding that Claimant’s claim against the City was time-barred because the antecedent complaint against the State was filed in the Tennessee Claims Commission after expiration of the one-year limitations period, and therefore, the ninety-day window under Tenn. Code Ann. 20-1-119 to file suit against the City, as a comparative tortfeasor, was never triggered. The Court of Appeals reversed, determining that Claimant’s written notice of his claim against the State, filed with the Division of Claims Administration within the limitations period, was an “original complaint” within the meaning of section 20-1-119, and therefore, the lawsuit against the City was timely. The Supreme Court reversed, holding (1) the complaint, not the written notice of claim, is the “original complaint” under section 20-1-119, and therefore, the ninety-day window to name a non-party defendant as a comparative tortfeasor was not triggered in this case; and (2) the tolling provision in the Claims Commission Act is not applicable to toll the statute of limitations for a claim against a municipality filed under Tennessee’s Governmental Tort Liability Act. View "Moreno v. City of Clarksville" on Justia Law

Plaintiff brought a statutory retaliatory discharge claim in the circuit court against the City of LaFollette pursuant to the Tennessee Public Protection Act (TPPA). Plaintiff requested a trial by jury. The trial court determined that Plaintiff was entitled to a jury trial on his TPPA claim. The court of appeals reversed, concluding that the Governmental Tort Liability Act (GTLA) applies to claims brought against a municipality pursuant to the TPPA, thus requiring the claim to be tried without a jury. The Supreme Court affirmed on different grounds, holding (1) the GTLA does not apply to TPPA claims against governmental entities; but (2) there is no constitutional or statutory right to trial by jury for TPPA claims filed in the circuit court. View "Young v. City of Lafollette" on Justia Law

Plaintiff sued Hospital Housekeeping Systems (the Company) in the United States District Court for the Middle District of Tennessee after the Company refused to hire her because she had filed a workers’ compensation claim incurred while working for a previous employer. The federal district court certified a question of law to determine whether Plaintiff had a cause of action under the Tennessee Workers’ Compensation Act against the Company for failure to hire under the circumstances of this case. The Supreme Court held that a job applicant does not have a cause of action under the Act against a prospective employer for failure to hire if the prospective employer refused to hire the applicant because he or she had filed, or was likely to file, a workers’ compensation claim against a previous employer. View "Yardley v. Hosp. Housekeeping Sys., LLC" on Justia Law

After a jury trial, Defendant was convicted of rape of a child. During trial, when the prosecution made election of the facts it was relying upon to establish the charge, the prosecution mistakenly identified the method of sexual penetration. This error was repeated in the jury instruction concerning the election. Defendant appealed, challenging only the sufficiency of the evidence to support his conviction. The Court of Criminal Appeals affirmed. In affirming the conviction, the Court of Criminal Appeals sua sponte raised this issue of whether the error in the State’s election of offenses constituted reversible error. The court concluded that the State’s inaccurate election error was harmless. The Supreme Court affirmed, holding (1) the Court of Criminal Appeals erred by failing to subject the election issue to plain error analysis; but (2) after reviewing the record pursuant to the plain error doctrine, and under the circumstances of this case, the election error did not entitle Defendant to relief. View "State v. Knowles" on Justia Law

Plaintiffs filed suit against Defendants, who for years enjoyed the continuous and exclusive possession of their lands, to settle a boundary dispute. As a result of the boundary litigation Defendants discovered that their ancestors had acquired title during the “gap years” and, consequently, had owned the lands as tenants in common with no right of survivorship rather than tenants by the entirety. Proceeding as third-party plaintiffs, Defendants filed a third-party complaint against descendants of their ancestors, who each claimed an ownership interest in the disputed lands by inheritance, seeking to quiet title to the disputed lands. The trial court granted summary judgment in favor of the third-party defendants. On remand, Defendants amended their third-party complaint, asserting absolute fee simple title by prescription. The trial court again denied relief. The court of appeals affirmed, holding that the third-party defendants’ ignorance of their status as co-tenants in common with their relatives prevented Defendants from taking title by prescription. The Supreme Court reversed, holding that each of the elements of title by prescription had been satisfied in this case, and therefore, the third-party defendants failed to rebut the presumption of title in favor of Defendants. View "Roberts v. Bailey" on Justia Law