Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) the sentence of death was not excessive, disproportionate, or imposed arbitrarily; (3) the evidence was sufficient to support the jury's finding of the statutory aggravating circumstances beyond a reasonable doubt; and (4) the evidence supported the jury's finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt. View "State v. Pruitt" on Justia Law

The issue for the Supreme Court's review in this matter centered on whether the return proof of service 412 days after issuance of the summons precluded a plaintiff from relying upon the original commencement of the lawsuit to toll the running of the statute of limitations. The Court concluded that the plain language of Tennessee Rules of Civil Procedure 3 and 4.03 did not condition the effectiveness of the original commencement to toll the statute upon prompt return of proof of service. The Court reversed the Court of Appeals who affirmed the trial court in dismissing the plaintiff's lawsuit. The case was remanded to the trial court to determine whether service of process took place within ninety days of the summons. If so, plaintiff could then rely on the original commencement of the suit to toll the statute of limitations. View "Fair v. Cochran" on Justia Law

The issue before the Supreme Court in this case centered on the appropriate response when a trial court learns during a jury's deliberations that a juror exchanged Facebook messages with one of the State's witnesses during the trial. The trial court declined the defendant's request to hold a hearing to question the juror and witness to ascertain whether the communications required a mistrial. The appellate court concluded that the trial court did no err in declining the request for a hearing. The Supreme Court disagreed, however, vacated the judgment and remanded the case for a hearing. View "Tennessee v. Smith" on Justia Law

The issue before the Supreme Court in this case involved grandparents' visitation rights and the applicable burden of proof and standards trial court should apply when grandparents and parents seek to modify and terminate, respectively, court-ordered grandparent visitation. The Court held that the burden of proof is upon the grandparent or parent seeking the modification or termination to demonstrate, by a preponderance, that both a material change in circumstances has occurred and that change is in the child's best interests. View "Lovlace et al. v. Copley et al." on Justia Law

The issue before the Supreme Court in this matter centered on whether the petitioner was entitled to seek post-conviction relief from a civil judgment that found her in criminal contempt and imposed sanctions. The Court held that a criminal contempt adjudication under Tennessee Code Annotated 29-9-102 (2012) does not amount to a criminal conviction under the general criminal laws for the purposed of the Post-Conviction Procedure Act. Accordingly, the Court affirmed the Court of Criminal Appeals, which affirmed dismissal of the petition. View "Baker v. Tennessee" on Justia Law

A mother sued Ford Motor Company on behalf of her six-year-old son, whose spine was fractured in a car wreck, alleging that the defective design of the seatbelt in the vehicle caused her son's permanent paralysis and other injuries. The jury returned a $43.8 million verdict for compensatory damages. Ford's share of the verdict, based on its degree of fault, was $6,570,000. Ford filed a motion for a new trial, arguing that the verdict was excessive. The trial court denied the motion. The court of appeals, however, determined that the verdict was excessive and remanded the case with a suggestion of remittitur from $43.8 million to $12.9 million. The suggested remittitur would reduce Ford's share of the verdict to $1,935,000. The Supreme Court reversed the judgment of the court of appeals and reinstated the jury's verdict, holding (1) the court of appeals had the authority to suggest a remittitur even though Ford did not request it; but (2) the court of appeals erred in remitting the verdict to $12.9 million, as the jury's verdict was supported by material evidence and was within the range of reasonableness. Remanded. View "Meals ex rel. Meals v. Ford Motor Co." on Justia Law

Employee suffered a right shoulder injury while working for Employer. After a benefit review conference in the Department of Labor and Workforce Development ended in an impasse, Employee filed suit for workers' compensation benefits. Prior to trial, Employer requested the appointment of an independent medical examiner pursuant to the medical impairment rating (MIR) process in Tenn. Code. Ann. 50-6-204(d)(5). Because the suit had already been filed, the trial court denied the request and subsequently awarded compensation to Employee. The Supreme Court vacated the judgment and remanded for consideration of the constitutionality of the MIR process. On remand, the trial court concluded (1) section 50-6-204(d)(5), which requires the courts to consider the opinion of an independent medical examiner under that section as presumptively accurate, is an unconstitutional infringement upon the powers of the judiciary; and (2) in the alternative, the statutory presumption was overcome in this case. The Supreme Court reversed in part, holding (1) the MIR process does not violate constitutional principles; and (2) the evidence in this case did not clearly and convincingly rebut the statutory presumption. Remanded. View "Mansell v. Bridgestone Firestone N.A. Tire, LLC" on Justia Law

Certain amplified music concerts were conducted on farm land in a rural county. The county board of zoning appeals later ordered the business owners who hosted the concerts to limit the concerts to one per year, but the business owners defied the order. Plaintiff, a neighborhood property owner, filed suit seeking to enforce the zoning authority's decision and to abate the concerts as a common-law nuisance. The trial court granted Defendants' motion to dismiss, concluding (1) the concerts were exempted from local land use regulations because they qualified as "agriculture"; and (2) the Tennessee Right to Farm Act (Act) precluded nuisance liability. The Supreme Court reversed, holding (1) the concerts were not "agriculture" for the purpose of the zoning laws; and (2) the Act did not apply to the music concerts, and Plaintiff presented a prima facie case of common-law nuisance. Remanded. View "Shore v. Maple Lane Farms, LLC" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

A group of sergeants employed within the county sheriff's office were paid varying amounts within an established pay range. The sergeants filed a grievance regarding the pay disparities. The sheriff's department civil service board upheld the grievance and ordered the sheriff to equalize the pay of all the sergeants in the sheriff's office. On appeal, the county chancery court declared the board's ruling null and void, holding that the board did not have the authority to order pay equalization. The court of appeals agreed that the board exceeded its statutory authority but remanded the cause to the board so it could direct the sheriff to pay all sergeants the same hourly rate. The Supreme Court reversed, holding (1) in the absence of proof that the sheriff violated state law or the sheriff's department civil service manual, the board lacked the power to order salary equalization; and (2) the board exceeded its authority in ordering the sheriff to correct the pay disparity, as there was no proof the sheriff violated state law, and the civil service manual specifically gave the sheriff authority to make individual pay determinations. View "Hammond v. Harvey" on Justia Law