Justia Tennessee Supreme Court Opinion Summaries

Employee worked for Employer assembling engine heads and attaching them to engine blocks. Employer ceased working after he sustained bilateral thoracic outlet syndrome, bilateral shoulder injuries, and a herniated disc in his neck. Employee filed this workers’ compensation action alleging that he received his injuries as a result of his work and that he was permanently and totally disabled by the injuries. The trial court concluded that Employee’s neck injury was not compensable and awarded eighty percent permanent partial disability for his other injuries. Both parties appealed. The Supreme Court affirmed, holding (1) the evidence did not preponderate against the trial court’s finding that Employee did not sustain a compensable neck injury; and (2) the award was not excessive. View "Watters v. Nissan N. Am., Inc." on Justia Law

Defendant was convicted of rape of a child and sentenced to twenty-five years' imprisonment. The Court of Criminal Appeals affirmed, holding (1) the trial court erred by allowing the prosecution to introduce the child victim’s prior consistent statement before the child’s credibility had been challenged and by ruling that if Defendant chose to testify the prosecution would be allowed to ask him whether he had previously been arrested or convicted of a felony, but (2) these errors were neither individually nor cumulatively prejudicial. The Supreme Court reversed and remanded for a new trial, holding that the cumulative effect of the two trial errors was prejudicial and entitled Defendant to a new trial. View "State v. Herron" on Justia Law

Defendant was convicted of two counts of felony murder in the perpetration of a first degree burglary and other crimes. The jury sentenced Defendant to death for the murder of one victim and to life imprisonment for the murder of the second victim. The Court of Criminal Appeals and Supreme Court affirmed on appeal. Defendant subsequently field a petition for post-conviction relief, alleging that he received ineffective assistance of counsel. On review, the Supreme Court granted Defendant a delayed appeal based upon the lack of meaningful representation during the original direct appeal. Upon remand, Defendant moved for a new trial and an accompanying petition for writ of error coram nobis. The circuit court denied relief as to all claims. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding (1) Defendant failed to establish that witness credibility was such an overriding issue that the trial judge was unable to consider the motions for new trial; (2) Defendant was not entitled to a new trial based upon “newly discovered evidence”; (3) the use of shackles in this instance was appropriate; and (4) the evidence at trial was sufficient to support Defendant’s convictions. View "State v. Hall" on Justia Law

After law enforcement officers discovered child pornography on Defendant’s home computer, Appellant was found guilty of felony sexual exploitation of a minor by knowingly possessing over 100 images of child pornography. The State then filed a complaint for judicial forfeiture against Appellant. Because foreclosure proceedings were already underway, the trial court enjoined the mortgage lender from disbursing to Appellant any excess proceeds from the anticipated foreclosure sale. After Appellant’s home was sold at auction and a trial was held on the complaint for forfeiture, the trial court ordered forfeiture of the proceeds from the sale of Appellant’s home. The court of appeals affirmed. The Supreme Court reversed, holding (1) in forfeiture proceedings, the seizing authority is required to present affirmative proof that it complied with both the procedural and the substantive requirements in the forfeiture statutes; (2) both the procedural and the substantive provisions of the forfeiture statutes must be strictly construed; and (3) the State in this case failed to show that it complied with the procedural requirements in the forfeiture statutes. View "State v. Sprunger" on Justia Law

Defendant’s minor daughter was diagnosed with a rare form of cancer and died at the age of fifteen. Defendant was indicted for neglect of a child under the age of eighteen based on her failure to obtain adequate medical treatment for her daughter. Defendant moved to dismiss the charge, arguing that the “spiritual treatment” exemption within the child abuse and neglect statute, which precludes the prosecution of parents who, under certain circumstances, provide treatment through prayer alone in lieu of medical treatment, is unconstitutional. The trial court rejected Defendant’s constitutional claims and denied her motion to dismiss. After a trial, the trial court concluded that Defendant did not qualify for the spiritual treatment exemption and found her guilty of child neglect. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the spiritual treatment exemption is not unconstitutionally vague; and (2) because the exemption may be elided without invalidating the remainder of the child abuse and neglect statute, Defendant’s remaining constitutional challenges would not afford relief. View "State v. Crank" on Justia Law

Employee worked for Employer for thirty-seven years. After his retirement, Employee sought workers’ compensation benefits based upon hearing loss he sustained, especially at frequency levels of sound above 3000 hertz. At issue during trial was the applicability of the American Medical Association’s Guides to the Evaluation of Permanent Impairment (AMA Guides) to Employee’s hearing loss. The AMA Guides provide an impairment rating formula for hearing loss only up to 3000 hertz but do not rate the level of impairment for hearing losses over 3000 hertz. The trial court awarded a thirty percent vocational disability, not only for the anatomical impairment between 2000 and 3000 hertz but also for the impairment between 3000 and 4000 hertz. The Supreme Court affirmed, holding (1) although the AMA Guides do not address the effect of hearing loss at levels higher than 3000 hertz, there was evidentiary support for the trial court’s determination that expert testimony established an “appropriate” method for rating the impairment in a manner “used and accepted by the medical community”; and (2) the evidence clearly established a hearing impairment above 3000 hertz. View "Lambdin v. Goodyear Tire & Rubber Co." on Justia Law

In this health care liability case, Plaintiffs, before filing their health care liability complaint, gave Defendants written notice pursuant to Tenn. Code Ann. 29-26-121(a)(1). Plaintiffs subsequently voluntarily dismissed their case. The next year, Plaintiffs filed a new complaint, raising the same claims against the same defendants. Plaintiffs did not give Defendants pre-suit notice before filing the second action. The trial court dismissed the complaint with prejudice for Plaintiffs’ failure to comply with the notice requirement of section 29-26-121(a)(1). The Court of Appeals reversed, determining that, since the complaints were essentially identical, the statute required only that Defendants be notified once. The Supreme Court reversed and dismissed the action without prejudice, holding (1) section 29-26-121(a)(1) requires that plaintiffs notify prospective defendants of a forthcoming health care liability lawsuit before the filing of each complaint, and the sanction for failure to comply with the statute is dismissal without prejudice; and (2) Plaintiffs in this case failed to provide the required pre-suit notice. View "Foster v. Chiles" on Justia Law

Defendant pleaded guilty to one count of possession of marijuana with intent to sell or deliver within 1,000 feet of a school zone, and other offenses. At the sentencing hearing, Defendant requested that the trial court place her on judicial diversion. The trial court denied Defendant’s request for judicial diversion, reasoning that there was a low likelihood that Defendant would be rehabilitated by judicial diversion. The Court of Appeals reversed the trial court’s denial of judicial diversion, concluding that the trial court failed to consider and weigh on the record all of the relevant factors in denying judicial diversion. The Supreme Court reinstated the trial court’s judgments, holding (1) the mandatory minimum service requirement of the Drug-Free School Zone Act does not render offenses under the Act ineligible for judicial diversion; and (2) although the trial court in this case failed adequately to address the appropriate factors on the record, Defendant’s request to be placed on judicial diversion was properly denied. View "State v. Dycus" on Justia Law

Plaintiff contracted to sell Defendants certain real property. The contract provided that Plaintiff would retain ownership of a sixty-foot wide strip of property to provide access to her remaining property, but the warranty deed failed to include the reservation. When it became difficult for Plaintiff to access her property due to improvements on the purchased real property, Plaintiff sued Defendants, alleging, among other claims that were subsequently dismissed, breach of contract. The trial court ruled for Plaintiff on the breach of contract claim and awarded her $650,000 in damages. The Court of Appeals reversed, concluding that the gravamen of Plaintiff’s prevailing claim was injury to real property, and therefore, the claim was barred by the three-year statute of limitations applicable to “actions for injuries to personal or real property.” The Supreme Court reversed, holding that Plaintiff’s claim was not barred by the three-year statute of limitations because the gravamen of Plaintiff’s prevailing claim was breach of contract, to which the six-year statute of limitations for “actions on contracts not otherwise expressly provided for” applied. View "Benz-Elliott v. Barrett Enters., LP" on Justia Law

In 2011, the Department of Children's Services (DCS) filed a petition to terminate Father’s parental rights to his child. In 2013, the juvenile court terminated the parental rights of Father. The court of appeals reversed, holding that DCS was required to make reasonable efforts to assist Father, and reasonable efforts were not made. At issue was whether, in a petition to terminate the parental rights of a biological parent, the State is required to prove that it made reasonable efforts to reunify the parent with the child as a precondition to termination. The Supreme Court reversed the court of appeals in this case, holding that, pursuant to Tenn. Code Ann. 36-1-113, the State need not prove that it made reasonable efforts as an essential component of its petition to terminate parental rights. In so holding, the Court overruled In re C.M.M. and its progeny to the extent the cases required the State to prove reasonable efforts as an essential component of the termination petition. View "In re Kaliyah S." on Justia Law