Justia Tennessee Supreme Court Opinion Summaries

A prisoner filed a petition for a writ of error coram nobis, a legal order allowing a court to correct its original judgment, long after the one-year limitations period had expired. The petition was based on new evidence that the prisoner claimed demonstrated his actual innocence. The coram nobis court held a hearing and determined that the new evidence did not show that the prisoner was actually innocent of the crimes of which he was convicted. As a result, the court dismissed the petition as untimely.The Court of Criminal Appeals reversed the coram nobis court's decision, arguing that the prisoner had met the requirements for tolling, or delaying, the statute of limitations. The appellate court remanded the case for a hearing on the allegations in the petition.The Supreme Court of Tennessee disagreed with the appellate court's decision. The Supreme Court held that if a petition for a writ of error coram nobis is not timely filed and seeks tolling of the statute of limitations, it must be based on new evidence that clearly and convincingly shows that the petitioner is actually innocent of the underlying crime. The court found that the prisoner's new evidence did not meet this standard. Therefore, the Supreme Court reversed the decision of the Court of Criminal Appeals and affirmed the decision of the coram nobis court, dismissing the petition as untimely. View "Clardy v. State" on Justia Law

This case involves a conservatorship dispute over Susan Davis Malone. Two attorneys involved in the case filed two motions requesting the trial judge to recuse himself. The first recusal motion was denied and affirmed on appeal. The second recusal motion was also denied. The attorneys then filed a second petition for recusal appeal, arguing that trial court orders entered after the Court of Appeals issued its opinion in the first recusal appeal, but before the mandate issued, are void for lack of subject matter jurisdiction.The Court of Appeals agreed with the attorneys and held that the orders were void. The counterpetitioners and co-conservators then filed an accelerated application for permission to appeal in the Supreme Court of Tennessee.The Supreme Court of Tennessee granted the application and reversed the judgment of the Court of Appeals. The court held that the stay imposed by the Court of Appeals in the first recusal appeal did not divest the trial court of subject matter jurisdiction over the case. The court also held that the attorneys waived any other argument that orders entered by the trial court should be vacated because they were entered prior to issuance of the mandate. The case was remanded for further proceedings consistent with this decision. View "In Re Conservatorship of Malone" on Justia Law

The case involves a slip and fall incident at a Trader Joe's grocery store in Nashville, Tennessee. The plaintiff, Melissa Binns, alleged that she slipped and fell due to the negligence of an employee who was stocking shelves in a disorganized manner, causing a package of tofu to fall and spill liquid on the floor. Binns filed a complaint against Trader Joe's East, Inc., alleging premises liability, negligent training, and negligent supervision. Trader Joe's sought to dismiss the negligent training and supervision claims, arguing that these claims should be dismissed when asserted concurrently with a premises liability claim and that the plaintiff's direct negligence claims were no longer viable due to the defendant admitting it was vicariously liable for the conduct of its employee.The trial court rejected both of Trader Joe's arguments and denied its motion for partial judgment on the pleadings. The court granted permission for an interlocutory appeal, which was denied by the Court of Appeals. Trader Joe's then appealed to the Supreme Court of Tennessee, which granted review.The Supreme Court of Tennessee held that the preemption rule, which would dismiss direct negligence claims when a defendant admits vicarious liability, is incompatible with Tennessee's system of comparative fault and declined to adopt it. The court also declined to adopt the rule proposed by Trader Joe's that "negligent activity" claims cannot be asserted alongside premises liability claims. As a result, the court affirmed the trial court's order denying Trader Joe's motion for partial judgment on the pleadings and remanded the case back to the trial court for further proceedings. View "Binns v. Trader Joe's East, Inc." on Justia Law

The Supreme Court of Tennessee heard the appeal of Tony Thomas and Laronda Turner, both convicted of three counts of first-degree premeditated murder stemming from a 2015 triple homicide in Memphis. The defendants were members of the Vicelords gang, and the murders were allegedly conducted in retaliation for a previous killing. Their trial relied heavily on the testimony of co-defendant Demarco Hawkins, whose trial was severed and who testified against them. Mr. Thomas and Ms. Turner appealed their convictions, alleging that the prosecution breached the requirements of Brady v. Maryland by failing to produce inconsistent statements made by Mr. Hawkins, and that the evidence was insufficient to support Ms. Turner’s murder convictions.The Supreme Court found that the State did not breach its obligations under Brady with regard to Mr. Thomas. However, the Court determined that the evidence was insufficient to sustain Ms. Turner’s convictions because Mr. Hawkins’ testimony was not adequately corroborated, leading to a reversal of her convictions. In addition, the Court abolished Tennessee’s common law accomplice-corroboration rule, which required some level of independent corroboration for accomplice testimony to be used in securing a conviction, but only applied this change prospectively. View "State v. Thomas" on Justia Law

In a wrongful death action against an assisted-living facility, the Supreme Court of Tennessee held that the claims were subject to arbitration as per an agreement signed by the deceased's attorney-in-fact. The court clarified two key points. First, signing an optional arbitration agreement is not a "health care decision" under the Durable Power of Attorney for Health Care Act. Second, the attorney-in-fact had the authority to sign the arbitration agreement on the deceased's behalf, considering the durable power of attorney gave her the power to act for him in "all claims and litigation matters". The court further ruled that the deceased's son, who brought the wrongful death action, was bound by the arbitration agreement because his claims were derivative of his father's. Consequently, the court reversed the decision of the Court of Appeals and remanded the case to the trial court.In the case, Granville Williams, Jr. died while residing at an assisted-living facility run by Smyrna Residential, LLC. His son James Williams filed a wrongful death action against the facility. The decedent's daughter, acting as his attorney-in-fact under a power of attorney, had signed an arbitration agreement with the facility at the time of his admission. The arbitration agreement was not a condition of admission to the facility. The key issues were whether the attorney-in-fact had the authority to sign the arbitration agreement and whether the son, who was not a party to the agreement, was nevertheless bound by it. View "Williams v. Smyrna Residential, LLC" on Justia Law

A man, David Wayne Eady, who was charged with multiple robberies in Nashville over a month, appealed the decision of the Court of Criminal Appeals which denied his motion to disqualify the District Attorney General’s Office from prosecuting his case. Eady argued that the District Attorney General's office should be disqualified because the District Attorney had represented him in a previous case approximately thirty years earlier. The Supreme Court of Tennessee disagreed, finding that the District Attorney did not have an actual conflict of interest under the Rules of Professional Conduct because the current case and the previous case were not "substantially related." The court also rejected the defendant’s argument that the appearance of impropriety should disqualify the District Attorney General’s Office, noting that the Rules of Professional Conduct did not retain the concept of appearance of impropriety.Eady also argued that his trial was improperly conducted as a single trial for multiple offenses under the theory that the separate crimes were all parts of a larger, continuing plan. The Supreme Court of Tennessee agreed with Eady on this point, finding that the trial court erred in denying his motion to sever the offenses. The court held that the evidence did not support a finding that the offenses were parts of a larger, continuing plan, and remanded the case for a new trial on one of the counts. View "State v. Eady" on Justia Law

The Supreme Court affirmed the judgment of the Workers' Compensation Appeals Board (appeals board) affirming the judgment of the Court of Workers' Compensation Claims (trial court) ordering Employer to pay Employee's attorney's fees and costs under Tenn. Code Ann. 50-6-226(d)(1)(B), holding that there was no error.Employee filed a petition for benefit determination seeking additional medical treatment after injuring his hip while working for Employer. The trial court ordered Employer to provide separate panels of specialists to treat Employee's hip and back. Employee subsequently filed another petition for benefit determination seeking temporary disability benefits. Employer agreed pay the requested temporary disability benefits. Thereafter, the trial court ordered Employer to pay attorneys' fees and costs to Employee's attorney. The appeals board affirmed. The Supreme Court affirmed, holding that the trial court did not err in ordering Employer to pay Employee's attorneys' fees and costs under section 50-6-226(d)(1)(B). View "Earheart v. Central Transport" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the order of the trial court granting summary judgment in favor of a homeowners' association (HOA) in this dispute between the HOA and a property owner, holding that the property owner was prohibited from using his property as a short-term rental.Plaintiff purchased a home in a vacation community with the intention to use it as a short-term rental. While at the time of purchase the property was subject to covenants requiring that the home be used for "residential and no other purposes," several years later the covenants were amended to allow leases with minimum lease terms of thirty days. Because Plaintiff continued to lease his property for terms of fewer than thirty days the HOA notified him that he was in violation of the amendments. Plaintiff responded by bringing this lawsuit seeking a declaratory judgment that he was not prohibited from using his property as a short-term rental. The HOA counterclaimed for declaratory and injunctive relief. The trial court granted summary judgment for Defendant. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) the HOA's covenants did not prohibit his short-term rentals; but (2) the amendments prohibited Plaintiff's short-term rentals. View "Pandharipande v. FSD Corp." on Justia Law

The Supreme Court affirmed the two pretrial orders of the trial court challenged by the defendant physician in a health care liability action in this interlocutory appeal, holding that this Court declines to modify its holding in George v. Alexander, 931 S.W.2d 517 (Tenn. 1996), and that the collateral source rule remains in effect in this case.The first pretrial order excluded evidence that a nonparty physician was the cause-in-fact of the claimant's injuries because Defendant did not amend his answer to include that allegation, as required under Tenn. R. Civ. P. 8.03, as applied in George. In the second order, the trial court held that Tenn. Code Ann. 29-26-199, a provision that partially abrogates the common-law collateral source rule in health care liability actions, did not abrogate the collateral source rule under the facts of this case. The Supreme Court affirmed both pretrial rulings at issue in this interlocutory appeal and remanded the case for further proceedings, holding that the trial court did not err. View "Crotty v. Flora" on Justia Law

The Supreme Court affirmed the decision of the court of criminal appeals reversing the trial court's sentence imposed in connection with Defendant's plea of guilty to vehicular homicide by intoxication and other offenses, holding that the clear and precise language of the 2017 amendment to the probation eligibility statute, Tenn. Code Ann. 40-35-303, prohibits all forms of probation for a defendant convicted of vehicular homicide by intoxication.Defendant pleaded guilty to vehicular homicide by intoxication, aggravated assault, resisting arrest, and driving without a license. The trial court imposed a sentence of ten years in prison, largely suspended to probation with periodic weeks of confinement for the first three years. The court of criminal appeals reversed and ordered Defendant to serve the full sentence in confinement, concluding that the 2017 amendment to the probation eligibility statute expressly prohibits probation of any kind for criminal defendants convicted of vehicular homicide by intoxication. The Supreme Court affirmed, holding that the clear and precise language of section 40-35-303 prohibits defendants convicted of vehicular homicide by intoxication from receiving any form of probation, including periodic and split confinement sentences. View "State v. Robinson" on Justia Law