Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated burglary and other charges. The trial judge did not expressly accept or approve of the jury’s verdict. After Defendant’s trial and before the sentencing hearing, the trial judge left the bench and a successor judge was designated. The designated judge held a sentencing hearing, sentenced Defendant, and transferred the matter to a different division for further proceedings. Defendant moved for a new trial, alleging that a successor judge could not act as the thirteenth juror because witness credibility was the “over-riding issue.” A successor judge conducted the hearing on the motion. The trial court denied the motion. The Court of Criminal Appeals reversed on the thirteenth juror issue. The Supreme Court reversed the judgment of the Court of Criminal Appeals and reinstated the judgments of the trial court, holding that the successor judge in this correctly determined that he could perform the function of the thirteenth juror and could independently weigh and assess the evidence adduced at Defendant’s trial so as to prevent a miscarriage of justice by the jury. View "State v. Ellis" on Justia Law

Three patients, who were injured in unrelated motor vehicle accidents, were all treated at the Regional Medical Center at Memphis (Hospital). In each case, either the patient’s insurance company or TennCare paid the Hospital the full amount of the adjusted charges for their case. However, the Hospital refused to release the lien it had perfected under the Tennessee Hospital Lien Act as it awaited recovery from the third-party tortfeasors the full, unadjusted amount of the hospital lien. The patients filed suit. The trial court dismissed the suit, but the Court of Appeals reversed, determining that the hospital could not maintain its lien because each of the patients’ debts had been extinguished. The Supreme Court affirmed in part and reversed in part, holding (1) except for the unpaid co-pays and deductibles, which are a patient’s responsibility, neither the Act nor the Hospital’s contracts with the patients’ insurance companies authorized the Hospital to maintain its lien after the patients’ insurance company paid the adjusted bill; and (2) one of the patients in this case had not extinguished her debt to the Hospital and was therefore not entitled to have the lien against her extinguished. View "West v. Shelby County Healthcare Corp." on Justia Law

Plaintiff filed a health care liability action against Defendant, who performed laser surgery on Plaintiff’s eye. Before trial, Defendant filed a motion seeking a waiver of Tenn. Code Ann. 29-26-115(b)’s contiguous state requirement, which would allow an ophthalmologist from Florida to testify as an expert witness. The trial court denied the motion, finding that Defendant had not established that appropriate witnesses would otherwise be unavailable. The court of appeals granted Defendant a Tenn. R. App. P. 10 extraordinary appeal and concluded that the trial court did not abuse its discretion in declining to waive the contiguous state requirement. The Supreme Court vacated the decision of the court of appeals, holding that the court of appeals improvidently granted Defendant’s application for extraordinary appeal. View "Gilbert v. Wessels" on Justia Law

After Plaintiff was discharged from his position of Chief of Police for the City of Red Bank, he filed suit in the Chancery Court against the City, alleging statutory retaliatory discharge in violation of the Tennessee Public Protection Act (TPPA) and age discrimination in violation of the Tennessee Human Rights Act (THRA). The Chancery Court (1) granted the City’s request to transfer the case to the Circuit Court; (2) granted the City’s request to proceed without a jury on the TPPA claim, citing Young v. Davis, which held that the Governmental Tort Liability Act (GTLA) controls TPPA claims against governmental entities, and such claims must be tried without a jury in the manner prescribed by the GTLA; but (3) upheld Plaintiff’s request for a jury on his THRA claim. The Court of Appeals reversed, holding that the GLTA applies to claims brought against a municipality pursuant to the THRA, and therefore, Plaintiff’s THRA claim was required to be tried without the intervention of a jury. The Supreme Court reversed, holding that the GTLA did not govern Plaintiff’s THRA claim and that the Legislature has afforded a statutory right to trial by jury on THRA claims filed against governmental entities in chancery court. View "Sneed v. City of Red Bank" on Justia Law

Defendant was indicted for seven counts of rape of a child victim. Two weeks before trial, the State sought to offer as evidence a video recording of a statement made by the victim to a forensic interviewer pursuant to Tenn. Code Ann. 24-7-123. The trial court denied admission of the video recording, concluding (1) the enactment of section 24-7-123 intruded upon the inherent authority of the judiciary to regulate the admissibility of evidence; (2) the video-recorded statement qualified as hearsay evidence not admissible under any exception to the rule against the admission of hearsay evidence; and (3) the admission of the video recording would violate Defendant’s right to confront witnesses. The Court of Criminal Appeals denied the State’s request for an interlocutory appeal. The Supreme Court reversed, holding (1) section 24-7-123 does not unconstitutionally infringe upon the powers of the judiciary and is a valid legislative exception to the general rule against the admission of hearsay evidence; and (2) the admission of video-recorded statements does not violate a defendant’s right of confrontation so long as the child witness authenticates the video recording and appears for cross-examination at trial. View "State v. McCoy" on Justia Law

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to death. Defendant’s conviction and sentence were affirmed on appeal. Defendant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court concluded that Defendant was not entitled to a new trial on the murder conviction but was entitled to a new sentencing hearing based on ineffective assistance of counsel. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to prove by clear and convincing evidence a reasonable probability that, but for the deficient performance of his trial counsel, the verdict of guilt for first degree murder would have been different. Remanded for a new sentencing hearing. View "Nesbit v. State" on Justia Law

Defendant was indicted on six counts of aggravated sexual battery and four counts of rape of a child for sexually abusing his stepdaughter. Defendant moved to suppress a surreptitiously-recorded conversation with the child’s mother, who was secretly cooperating with the police in their investigation of the abuse. The trial court denied the motion to suppress. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that the admission of Defendant’s recorded conversation with the child's mother did not violate his constitutional right against compelled self-incrimination because, under the totality of the circumstances, Defendant’s incriminating statements were admissible because they were made voluntarily. View "State v. Sanders" on Justia Law

After a jury trial, Defendant was found guilty of seven counts of rape of a child and two counts of aggravated sexual battery arising from the sexual abuse of his children. The court of criminal appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions because the State presented adequate evidence corroborating Defendant’s confession to his wife; (2) the trial court properly refused to suppress surreptitiously-recorded conversations between Defendant and his wife; (3) the trial court erred by admitting evidence that Defendant possessed and viewed adult pornography, but the error was harmless; and (4) any error in jury instructions given during trial that the mental state of “recklessness” could support a conviction for aggravated sexual battery was harmless beyond a reasonable doubt. View "State v. Clark" on Justia Law

A jury awarded $3 million in compensatory damages to Plaintiff after finding that Defendant, Plaintiff's employer, retaliated against Plaintiff in violation of Title VII of the Civil Rights Act of 1964 and the Tennessee Human Rights Act. The court of appeals reversed, concluding that Plaintiff failed to show that his supervisor knew of his protected activity before she took adverse action against him. The Supreme Court reversed the decision of the court of appeals, reinstated the jury verdict, and remanded, holding that the jury’s verdict was supported by material evidence from which the jury could infer that the supervisor knew that Plaintiff had filed a discrimination lawsuit when she engaged in retaliatory conduct against Plaintiff. View "Ferguson v. Middle Tenn. State Univ." on Justia Law

After a jury trial, Defendant was convicted of aggravated burglary and employment of a firearm during the commission of a dangerous felony. Defendant appealed, arguing that the trial court (1) erred by denying his request for a special jury instruction on the definition of actual and constructive possession as an element of employment of a firearm, and (2) erred by failing to instruct the jury on the crime of possession of a firearm during the commission of a dangerous felony as a lesser included offense. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err by refusing Defendant’s request for a special instruction on the definition of possession; and (2) possession of a firearm during the commission of a dangerous felony qualifies as a lesser included offense of employment of a firearm during the commission of a dangerous felony, but Defendant waived the issue and was not entitled to relief under the plain error doctrine. View "State v. Fayne" on Justia Law