Justia Tennessee Supreme Court Opinion Summaries

After Plaintiff was stopped for a moving violation, a law enforcement officer administered several field sobriety tests. The officer arrested Plaintiff for DUI because he had been driving in the wrong direction on a divided highway, smelled of alcohol, and admitted he had been drinking. Plaintiff filed a motion to suppress the evidence and to dismiss the charges of DUI and DUI per se. The trial court dismissed the charges, concluding that the officer lacked probable cause to arrest Plaintiff in light of his performance on the field sobriety tests. The Supreme Court reversed and reinstated the charges, holding that the officer had probable cause to arrest Plaintiff for DUI because, even considering Plaintiff’s successful performance on the field sobriety tests, Plaintiff’s moving violation, the odor of alcohol, and Plaintiff’s admission to drinking were sufficient to permit a prudent person to believe Plaintiff was driving under the influence of an intoxicant. View "State v. Bell" on Justia Law

After Plaintiff filed a health care liability action against Defendant, the General Assembly enacted Tenn. Code Ann. 29-26-121 and -122, which implemented pre-suit notice and certificate of good faith requirements. Plaintiff subsequently dismissed her original action and filed two successive actions. The second action did not comply with sections 29-26-121 and -122, but the third action complied with the statutes. Plaintiff filed a motion to consolidate her second and third actions. Defendant moved to dismiss, arguing that Plaintiff’s second action should be dismissed for failure to comply with the notice and certificate of good faith requirements and that her third action should be dismissed based on the doctrine of prior suit pending. The trial court denied the motions to dismiss. The Supreme Court granted Defendant’s application for extraordinary appeal. During the pendency of the appeal, Plaintiff voluntarily dismissed her second action. The Supreme Court affirmed the judgment of the trial court, holding that Plaintiff’s third complaint was timely filed because Plaintiff properly provided pre-suit notice of her claim prior to filing her third action and was entitled to a 120-day extension in which to refile her complaint. Remanded. View "Cannon ex rel. Good v. Reddy" on Justia Law

In 2000, Defendant pleaded guilty to two counts of attempted rape. In 2010, the Supreme Court filed its opinion in Ward v. State, in which the Court held that trial courts, before accepting a guilty plea to a crime carrying a mandatory sentence of lifetime community supervision, must inform the defendant desiring to plead guilty of the consequence of lifetime supervision. In 2011, Defendant filed a petition for relief under the Post-Conviction Procedure Act, alleging that his guilty pleas were not knowing or voluntary because he had not been informed that he would be subject to lifetime community supervision. The trial court concluded that Defendant was entitled to post-conviction relief because (1) Ward should be applied retroactively, and (2) the applicable statute of limitations should be tolled on due process grounds. The court of criminal appeals reversed. The Supreme Court affirmed, holding (1) the holding in Ward does not require retroactive application, and therefore, Defendant was not entitled to tolling under Tenn. Code Ann. 40-30-102(b)(1); and (2) Defendant’s case did not warrant due process tolling. View "Bush v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and aggravated burglary. Defendant appealed, challenging the sufficiency of the evidence. The court of criminal appeals affirmed the convictions and sentences, holding (1) the evidence of identification was sufficient as to both convictions; and (2) as to the aggravated burglary, the victim had not given his “effective consent” to the entry of the residence. The Supreme Court (1) affirmed the aggravated robbery conviction, holding that the identification evidence was sufficient as to both offenses; but (2) reversed the aggravated burglary conviction, holding that the evidence was insufficient as a matter of law to support the conviction because no reasonable factfinder could conclude that Defendant’s entry of the residence was without the victim’s “effective consent.” Remanded for a new trial on the lesser included offenses of aggravated criminal trespass and criminal trespass. View "State v. Pope" on Justia Law

Claimant was a licensed time-share salesperson who sold time-share interests at a resort. After resort management terminated the business relationship with Claimant, Claimant filed for state unemployment benefits. The Department of Labor and Workforce Development awarded benefits to claimant, concluding that the "qualified real estate agent" exclusion in the Tennessee Employment Security Law's definition of employment did not preclude Claimant from receiving unemployment benefits because Claimant was not a licensed real estate agent. The appeals tribunal and board of review affirmed. The chancery court reversed, determining that a time-share salesperson is a licensed real estate agent and therefore, Claimant was ineligible for unemployment benefits as a qualified real estate agent. The court of appeals reversed. The Supreme Court reversed the court of appeals, holding (1) a time-share salesperson is a licensed real estate agent within the Employment Security Law's qualified real estate agent exclusion; (2) Claimant satisfied the exclusion's criteria and was therefore a qualified real estate agent; and (3) consequently, Claimant was ineligible to receive unemployment compensation benefits. View "Westgate Smoky Mountains at Gatlinburg v. Phillips" on Justia Law

Plaintiff, an employee of the Tennessee Department of Correction (TDOC), filed this defamation claim against the State and the TDOC. After Plaintiff was demoted for violating the State's travel billing policy, the TDOC Commissioner responded to media inquires about Plaintiff's demotion. The Tennessee Claims Commission denied the State's motion for summary judgment in which the State argued that the Commissioner had an absolute privilege to make the allegedly defamatory statements to the media. The Supreme Court reversed, holding that the State was absolutely immune from Plaintiff's defamation claims that related to the Commissioner's statements in response to media inquiries about Plaintiff's demotion. View "Jones v. State" on Justia Law

Petitioner pled guilty to the felony charge of child neglect and to the misdemeanor charge of child abuse. About six months later, Petitioner for a petition for post-conviction relief, alleging that he received ineffective assistance of counsel based on trial counsel's failure to advise him of the immigration consequences of his plea and that his plea was unknowing and involuntary because the trial court failed to comply with Tenn. R. Crim. P. 11(b)(1)(J). The post-conviction trial court denied relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) trial counsel did not perform deficiently; and (2) the trial court's failure to comply with Rule 11(b)(1)(J) was harmless beyond a reasonable doubt. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder, first degree premeditated murder, and especially aggravated robbery. The trial court merged the murder convictions and imposed consecutive sentences of life for the murder and eighteen years for the especially aggravated robbery. As support for consecutive sentencing, the trial court ruled that Defendant qualified as a dangerous offender. The court of criminal appeals remanded to the trial court for a reconsideration of whether the sentences should be served concurrently or consecutively because the trial court had failed to specifically address underlying factors essential to a dangerous offender classification. The Supreme Court affirmed, holding (1) when a trial court places findings on the record to support its sentencing decision, the applicable standard of appellate review for a challenge to the imposition of consecutive sentences is abuse of discretion with a presumption of reasonableness; and (2) the trial court in this case failed to address the factors required to impose consecutive sentences based on the dangerous offender classification. Remanded for a new sentencing hearing. View "State v. Pollard" on Justia Law

Landlords brought an unlawful detainer action against Tenants to regain possession of the premises and recoup damages. The general sessions court later entered a default judgment granting Landlords possession of the property and a $42,500 judgment for past due rent and attorneys' fees. Tenants filed a notice of appeal and posted an appeal bond by depositing $250 cash with the clerk of court. Landlords filed a motion to dismiss, arguing that Tenants violated Tenn. Code Ann. 29-18-130(b)(2) by failing to post a bond equal to one year's rent. The circuit court denied the motion, concluding that a bond for one year's rent was unnecessary because Tenants had already surrendered possession of the property and vacated the premises. The Supreme Court affirmed the circuit court's denial of Landlords' motion to dismiss, holding that the circuit court did not err in determining that section 29-18-130(b)(2) does not require a tenant who has surrendered possession of the property to post a bond for one year's rent when appealing an adverse judgment of the general sessions court in an unlawful detainer action. View "Johnson v. Hopkins" on Justia Law

Plaintiff was the minor beneficiary of a $100,000 life insurance policy. Plaintiff filed a complaint against his financial guardian and the insurance company after the guardian misappropriated the insurance proceeds. The trial court entered judgments in favor of Plaintiff. The insurance company appealed. The court of appeals affirmed, concluding that, by entrusting the proceeds to the guardian, the insurance company breached its contractual duties. The Supreme Court reversed, holding (1) the insurance company acted in good faith when it relied upon the validity of a juvenile court order establishing a financial guardianship in making payment of the life insurance proceeds, and (2) therefore, the insurance company could not be liable for breach of contract. View "Hood v. Jenkins" on Justia Law