Justia Tennessee Supreme Court Opinion Summaries

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

The chief of police for the City of Burns had Plaintiff, a police officer, “fix” a traffic ticket for a relative. When Plaintiff complained to the mayor that the police chief had pressured him into illegal ticket fixing, Plaintiff was discharged. Plaintiff filed this lawsuit against the City of Burns, asserting a claim of retaliatory discharge pursuant to the Tennessee Public Protection Act (TPPA). The trial court granted summary judgment in favor of the City. The Supreme Court reversed, holding (1) the City’s assertion that it discharged Plaintiff because he violated the chain of command by reporting the ticket fixing to the mayor amounted to an admission that it retaliated against Plaintiff for refusing to remain silent about illegal activities, conduct that is protected under the TPPA; (2) the second reason proffered by the City for Plaintiff’s discharge, that he undermined the police chief’s authority with the other officers in the police department, is pretext for retaliation; and (3) thus, Plaintiff was discharged solely in retaliation for conduct protected under the TPPA. View "Williams v. City of Burns" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery of a store manager and four counts of especially aggravated kidnapping of four store employees. Defendant appealed, arguing that the trial court committed reversible error by failing to give a jury instruction based on the Supreme Court’s decision in State v. White. The Court of Criminal Appeals affirmed Defendant’s convictions, concluding that a White jury instruction was not required because the kidnapping and robbery charges did not involve the same victim. The Supreme Court affirmed, holding that a White jury instruction is not required when a defendant is charged with the kidnapping and robbery of separate victims. View "State v. Teats" on Justia Law

Defendant was tried on charges of kidnapping and robbery of a father, mother, and three children. At trial, a jury instruction based on the Supreme Court’s decision in State v. White was neither requested nor given. The jury convicted Defendant of five counts of especially aggravated kidnapping of the husband, wife, and three children; aggravated burglary of the husband’s residence; and two counts of aggravated robbery of the husband and wife. The Court of Criminal Appeals modified the conviction of aggravated robbery of the wife to aggravated assault and otherwise affirmed. The Supreme Court remanded the case for consideration in light of White. On remand, the Court of Criminal Appeals affirmed the convictions of especially aggravated kidnapping as to the three children but reversed the convictions of especially aggravated kidnapping as to the husband and wife and remanded those charges for a new trial . Defendant appealed the Court of Criminal Appeals’ holding that he was not entitled to a new trial for failure to receive a jury instruction as to the three kidnapping charges of the three children. The Supreme Court affirmed, holding that the White jury instruction was not required as to the offenses of especially aggravated kidnapping of the three children. View "State v. Williams" on Justia Law

Plaintiffs, five death-sentenced inmates, filed a declaratory judgment action against the Commissioner of the Tennessee Department of Correction (TDOC) and other TDOC officials challenging the constitutionality and legality of a 2014 statute that designated electrocution as an alternative method of execution and the constitutionality of electrocution as a means of execution. Defendants filed a motion to dismiss, arguing that Plaintiffs’ claims should be dismissed as unripe because the inmates were not currently subject to execution by electrocution and because the use of that method of execution in Tennessee was contingent on hypothetical, future, and speculative events. The trial court denied the motion, concluding that the claims were ripe because Plaintiffs were in danger of being electrocuted “in Tennessee’s electric chair.” The Supreme Court reversed and dismissed Plaintiffs’ electrocution claims as unripe, holding that because Plaintiffs were not currently subject to execution by electrocution and will not ever become subject to execution by electrocution unless one of two statutory contingencies occurs in the future, their claims challenging the constitutionality of the 2014 statute and electrocution as a means of execution are unripe and nonjusticiable. View "West v. Schofield" on Justia Law

Prentice Delon Hyler sought health care services from Action Chiropractic Clinic, LLC (Plaintiff) after she was injured in an automobile accident. Hyler executed an “Assignment of Rights” to Plaintiff for medical benefits payable to Hyler by Erie Insurance Exchange. Erie was the automobile liability insurance provider for the opposing driver involved in the accident. Erie and Hyler entered into a settlement agreement providing that Erie would pay Hyler $8,510 for claims relating to the accident. Plaintiff sued both Erie and Hyler seeking to recover the $5,010 it was owed from Hyler. The trial court granted Erie’s motion for summary judgment, concluding that the Assignment of Rights was not a valid assignment. The Supreme Court affirmed, holding that the assignment in this case was ineffective. View "Action Chiropractic Clinic, LLC v. Hyler" on Justia Law

A railroad employee with lung cancer brought this action against the railroad under the Federal Employers’ Liability Act, alleging that the railroad (1) had negligently exposed him to toxic materials that were contributing causes to his illness, and (2) was negligent per se by violating pertinent safety statutes or regulations. The jury rendered a verdict in favor of the plaintiff, concluding that the employee’s cancer and death were caused by the railroad’s negligence and by its negligence per se. The jury awarded $8.6 million in damages but then entered an amended verdict awarding the plaintiff $3.2 million. The trial court granted a new trial based on evidentiary and instructional issues and later entered an order of recusal. A substitute judge granted summary judgment for the railroad after excluding the plaintiff’s expert proof on the issue of causation. The court of appeals reversed and remanded for the original trial judge to enter judgment on either the original verdict or the amended verdict. The Supreme Court reversed, holding (1) the plaintiff’s expert proof was properly admitted at trial; but (2) the original judge erred by granting the railroad’s motion for a new trial and committed prejudicial error in assessing the amount of damages to be awarded. Remanded for a new trial as to damages only. View "Payne v. CSX Transp., Inc." on Justia Law

In this health care liability case Plaintiff sent Defendants pre-suit notice of the claim via FedEx. Defendants moved for summary judgment, alleging that Plaintiff failed to comply with the requirements of Tenn. Code Ann. 29-26-121(a)(3)(B) and (a)(4) by not using certified mail, return receipt requested, through the U.S. Postal Service. The trial court dismissed the complaint, concluding that strict compliance with the manner and proof of service requirements of sections 29-26-121(a)(3)(B) and (a)(4) was required. The court of appeals affirmed. The Supreme Court reversed, holding (1) the manner and proof of service prescribed by sections 29-26-121(a)(3)(B) and (a)(4) may be achieved through substantial compliance; (2) delivery of pre-suit notice by private commercial carrier and filing of proof with the complaint constitutes substantial compliance with sections 29-26-121(a)(3)(B) and (a)(4); and (3) because Defendants received notice and were not prejudiced by the manner of service, Plaintiff’s provision of pre-suit notice to Defendants through the use of FedEx and filing of proof with the complaint constituted substantial compliance with the manner and proof of service requirements of the pre-suit notice statute. Remanded. View "Arden v. Kozawa" on Justia Law