Justia Tennessee Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of attempted voluntary manslaughter, aggravated assault, and false imprisonment. Concluding that the separate convictions for attempted voluntary manslaughter and aggravated assault did not violate double jeopardy, the trial court declined to merge any of the convictions and imposed consecutive sentences totaling twenty-six years, eleven months, and twenty-nine days. The Court of Criminal Appeals affirmed the convictions and sentences. Defendant appealed, arguing that his sentences for attempted voluntary manslaughter and aggravated assault should be merged based upon the former double jeopardy principles set out in State v. Denton. The Supreme Court affirmed, holding (1) due process safeguards do not prohibit the retroactive application of the double jeopardy standard adopted in State v. Watkins, which was decided after the date of Defendant’s offenses; and (2) under Watkins, Defendant was not entitled to relief. View "State v. Feaster" on Justia Law

Buyer purchased a manufactured home from Sellers. The parties entered into a contract setting forth the terms of the sale and the parties obligations. The contract contained an arbitration provision under which Sellers retained the right to seek relief in a judicial forum for limited purposes. Buyer later brought a breach of contract action against Sellers, and Sellers filed a motion to compel arbitration. The trial court denied the motion to compel, holding that the non-mutuality remedies in the arbitration provision rendered it unconscionable and invalid. The court of appeals affirmed. The Supreme Court reversed, holding that Sellers’ retention of a judicial forum for limited purposes did not render the arbitration agreement unconscionable. View "Berent v. CMH Homes, Inc." on Justia Law

Plaintiff filed a medical malpractice action against Defendants. The trial court granted Plaintiff’s request to voluntarily dismiss the action without prejudice after Defendants moved to dismiss the action on the grounds that the certificate of good faith was noncompliant with the requirement of Tenn. Code Ann. 29-26-122(d)(4) that a certificate of good faith filed in a medical malpractice action disclose the number of prior violations of the statute by the executing party. Defendants appealed, arguing that the action should have been dismissed with prejudice because Plaintiff did not disclose that there were no prior violations by Plaintiff’s counsel. The court of appeals affirmed. The Supreme Court affirmed, holding that section 29-26-122(d)(4)’s requirement does not also require disclosure of the absence of any prior violations of the statute. View "Davis ex rel. Davis v. Ibach" on Justia Law

Doctor performed a spinal fusion on Patient. When Patient’s back pain worsened, Patient sued Doctor, alleging that Doctor failed to give him adequate information to enable him to give an informed consent to the surgery. In a pretrial deposition, Patient’s expert testified that to obtain informed consent, Doctor was required to inform Patient about all the potential risks that might arise from the surgery. The trial court granted Doctor’s motion to limit Patient’s expert witness testimony only to those risks that allegedly materialized and injured Patient. After a trial, the jury returned a verdict in Doctor’s favor. The Court of Appeals affirmed the trial court’s exclusion of the expert medical testimony. The Supreme Court reversed, holding that the trial court erred by excluding expert testimony regarding undisclosed medical risks that had not materialized, and this error, more likely than not, affected the jury’s verdict. Remanded for a new trial on the issue of informed consent. View "White v. Beeks" on Justia Law