Justia Tennessee Supreme Court Opinion Summaries

Plaintiff filed a civil action in the general sessions court against Defendant, alleging that Defendant provided substandard medical treatment to her. Following a bench trial, the general sessions court entered judgment in favor of Defendant. Plaintiff filed a notice of appeal the next day and deposited with the general sessions court clerk $211.50, which represented the amount of the standard court cost for an appeal to the circuit court plus state and local litigation taxes. The circuit court dismissed Plaintiff’s appeal for lack of subject matter jurisdiction because Plaintiff failed to file an appeal bond in an amount sufficient to secure the “costs of the appeal” under Tenn. Code Ann. 27-5-103. The court of appeals reversed the dismissal of Plaintiff’s case, concluding that payment of the standard court cost and litigation taxes satisfies the appeal bond requirement of section 27-5-103. The Supreme Court affirmed, holding that Plaintiff’s cash bond was sufficient to perfect her appeal to the circuit court. View "Griffin v. Campbell Clinic, P.A." on Justia Law

Plaintiff filed suit against three health care providers. The trial court granted motions for summary judgment dismissing all the claims against one of the providers. The trial court did not explain the grounds for its decisions and, rather, requested counsel for the provider to prepare orders establishing the rationale for the court’s ruling. In response, the provider’s counsel prepared “extremely detailed” orders essentially restating the arguments contained in the provider’s filings in support of its summary judgment motions. The trial court signed the orders over Plaintiff’s objections. The court of appeals vacated the contested orders because the trial court had failed to state the legal grounds for its decisions as required by Tenn. R. Civ. P. 56.04. The Supreme Court affirmed, holding that trial court failed to comply with Rule 56.04 because the summary judgment orders did not demonstrate that the court exercised its own independent judgment in reaching its decision. View "Smith v. UHS of Lakeside, Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of fabricating evidence and six counts of making a false report. Defendant filed a motion for a new trial. After a hearing, the trial court affirmed Defendant’s convictions for making a false report but reversed Defendant’s fabricating evidence convictions. The court of criminal appeals dismissed as multiplicitous two of Defendant’s convictions for making a false report, reinstated the convictions for fabricating evidence, and affirmed the remaining convictions. The Supreme Court (1) affirmed the court of criminal appeals’ reinstatement of Defendant’s convictions for fabricating evidence; (2) dismissed two of Defendant’s convictions for making a false report for lack of sufficient evidence; (3) dismissed two of Defendant’s convictions for making a false report as multiplicitous; and (4) affirmed the court of criminal appeals in all other respects. View "State v. Smith" on Justia Law

Defendant pled guilty to two counts of vehicular homicide and was sentenced to twenty-four years' imprisonment. Defendant twice appealed his sentence. On both appeals the court of criminal appeals remanded the case for resentencing, and on each remand the trial court imposed a twenty-four year sentence. No appeal was filed from the third sentencing order. Defendant subsequently filed a pro se petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance by failing to appeal the third sentencing order. At the post-conviction hearing, trial counsel testified that he and Defendant discussed a third appeal and that Defendant agreed that no appeal would be filed. The post-conviction court denied post-conviction relief, finding the testimony of trial counsel to be more credible than the testimony of Defendant and concluding that Defendant knew of his right to appeal and waived that right. The Supreme Court affirmed, holding (1) trial counsel’s failure to file a written waiver of appeal as required by Tenn. R. Crim. P. 37(d)(2) did not violate Defendant’s right to effective assistance of counsel; and (2) Defendant failed to prove by clear and convincing evidence his allegations of ineffective representation. View "Arroyo v. State " on Justia Law

Plaintiff filed a health care liability action against Defendant-health care providers. Six days before filing his complaint, Defendant sent a pre-suit notice of his potential claim to each Defendant by certified mail, return receipt requested, as permitted by Tenn. Code Ann. 29-26-121(a)(1). Defendants filed a motion to dismiss on the basis that Plaintiff failed to file with his complaint an affidavit of the person who had sent the pre-suit notice by certified mail. The trial court dismissed the complaint. The court of appeals affirmed but noted the harsh results strict compliance produces in cases such as this one where no prejudice is alleged. The Supreme Court reversed and reinstated the complaint, holding (1) the statutory requirement that an affidavit of the person who sent the pre-suit notice by certified mail be filed with the complaint may be satisfied by substantial compliance; and (2) Plaintiff substantially complied with the statute in this case. View "Thurmond v. Mid-Cumberland Infectious Disease Consultants, PLC " on Justia Law

Employee worked for Employer from 1977 through the date of the trial of this matter. Employee began having problems with his arms and hands in 2005. In 2009, Employee had carpal tunnel release surgery performed on his arms. Employee began having problems with his right thumb shortly after his surgeries. A surgical procedure to release the thumb was performed in 2010. In 2013, the trial court awarded permanent partial disability benefits to Employee but ruled that Employee’s injury should be apportioned to the arm, which was subject to an impairment “cap.” Employee appealed, arguing that the award should have been apportioned to the thumb, which was not subject to the cap. The Supreme Court affirmed, concluding that the trial court correctly chose to apportion Employee’s injury to the arm. View "Evans v. Fidelity & Guar. Ins. Co. " on Justia Law

Petitioner, a Mexican citizen, pleaded guilty to patronizing prostitution and was granted judicial diversion. Petitioner successfully completed his diversion, and his criminal record was subsequently expunged. Approximately three years after the entry of his plea, Petitioner filed a petition for post-conviction relief alleging that he was entitled to relief under Padilla v. Kentucky because his trial counsel failed to inform him of the immigration consequences of his plea. The trial court dismissed the petition on the grounds that it was time-barred. The court of criminal appeals affirmed the trial court’s summary dismissal of the petition, concluding that a petitioner whose record has been expunged may not obtain post-conviction relief. The Supreme Court affirmed, holding that the Post-Conviction Procedure Act may not be used to collaterally attack a guilty plea that has been expunged after successful completion of judicial diversion. View "Rodriguez v. State" on Justia Law

Plaintiff initiated this lawsuit challenging the constitutionality of the “Tennessee Plan,” which governs the way in which judges of the Tennessee appellate courts are initially selected and thereafter stand for election. The court of appeals upheld as constitutional the Judicial Nominating Commission/gubernatorial appointment under the Tennessee Plan, the retention election portion of the Tennessee Plan, and the election of the Tennessee intermediate appellate court judges on a statewide basis. The Special Supreme Court vacated in part and affirmed in part the judgment of the court of appeals, holding (1) the issue of the constitutional validity of the Judicial Nominating Commission/gubernatorial appointment process under the Tennessee Plan was moot because by the time the Court heard oral argument, the judicial nominating commission portions of the Tennessee Plan were no longer in effect; (2) the retention election portion of the Tennessee Plan satisfies the constitutional requirement that the judges of the appellate courts be elected by the qualified voters of the State; and (3) the election of judges to the court of appeals and court of criminal appeals on a statewide basis does not violate the state Constitution. View "Hooker v. Haslam" on Justia Law

On July 28, 2012, Michael Becker was injured when a Ford truck driven by his son, Phillip Becker, struck a light pole. Michael and his wife filed suit against Ford Motor Company. On August 26, 2013, Ford filed an answer claiming that the accident was caused by a person other than Ford. On October 1, 2013, the Beckers filed a motion to join Phillip as a party to whom fault could be apportioned and a motion to file an amended complaint. At issue before the Supreme Court was whether, after a defendant asserts a comparative fault claim against a non-party tortfeasor who was known to the plaintiff when the original suit was filed, Tenn. Code Ann. 20-1-119 permits the plaintiff to amend its complaint to assert a claim directly against the tortfeasor named by the defendant. The Court held (1) application of section 20-1-119 is not restricted to tortfeasors who were unknown to the plaintiff when its original complaint was filed; and (2) therefore, the statute permits a plaintiff to file an amended complaint against the tortfeasor named by the defendant within ninety days after the filing of the answer in which the defendant first asserts a comparative fault claim against the tortfeasor. View "Becker v. Ford Motor Co." on Justia Law

After being arrested and while in custody, Defendant admitted his involvement in Maurice Taylor’s killing. After a jury trial, Defendant was convicted of attempted aggravated robbery and first-degree felony murder. The court of criminal appeals reversed, concluding (1) the trial court erred in denying Defendant’s motion to suppress his pretrial confession because the confession was the result of an illegal arrest and detention; and (2) insufficient evidence supported the convictions because the State did not introduce sufficient evidence, other than Defendant’s confession, to corroborate the commission of the attempted robbery. The Supreme Court reversed and reinstated Defendant’s convictions and sentences, holding (1) the police had probable cause to arrest Defendant; and (2) Defendant’s confession did not require corroboration because he repeated his confession under oath at trial, but, had his extrajudicial confession required corroboration, the State presented sufficient evidence that this confession was trustworthy. View "State v. Bishop" on Justia Law