Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law

Decedent died following complications that arose when she received anesthesia. Decedent's husband (Plaintiff) filed suit against various health care providers, including Defendant, which contracted with the hospital to provide anesthesia services to its obstetric patients. Plaintiff alleged that Defendant was vicariously liable for the negligent acts of its corporate owner and president, a medical doctor, who was on call the night Decedent received the anesthesia but refused to come to the hospital to administer the anesthesia. Defendant failed to raise the statute of repose as a defense to the vicarious liability claim. After a jury trial, the trial court set aside the verdict for Defendants and granted a new trial. Defendant then moved to amend its answer to assert a repose defense and to dismiss the case based on the statute of repose. The trial court denied Defendant's motions, ruling that Defendant had waived the statute of repose defense. The Supreme Court affirmed, holding that Defendant failed to timely raise the statute of repose as an affirmative defense. View "Pratcher v. Methodist Healthcare Memphis Hosps." on Justia Law

Defendant was arrested on federal and state charges and taken into federal custody. After a trial in federal court, Defendant was convicted. Defendant was subsequently indicted by a Gibson County grand jury on the related state charges. After he was sentenced in federal court, Defendant was transported to Gibson County for an arraignment. Defendant was arraigned and then transferred back into federal custody. Defendant filed a motion to dismiss the state indictment for violations of the Interstate Agreement on Detainers (IAD), articles III and IV. Under article IV, an official of one jurisdiction may seek custody of a prison serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be shuttled back to the original place of imprisonment before the trial. The trial court denied the motion, and Defendant entered a conditional guilty plea. The court of criminal appeals affirmed the trial court's denial of Defendant's motion to dismiss. The Supreme Court reversed, vacated Defendant's conviction, and dismissed the indictment against Defendant with prejudice, holding that article IV of the IAD was violated when Defendant was transferred back to the federal detention center before being tried for the state charges. View "State v. Springer" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and tampering with physical evidence. The court of criminal appeals upheld Defendant's convictions and sentences. Defendant appealed, arguing (1) the trial court erred in declining his request for a jury instruction on defense of a third person, and (2) his abandonment of the murder weapon did not amount to tampering with physical evidence. The Supreme Court (1) affirmed Defendant's conviction for first degree murder, holding that the trial court properly denied Defendant's request for an instruction on defense of a third person; and (2) reversed Defendant's conviction for tampering with physical evidence, holding that Defendant did not "conceal" the murder weapon within the meaning of the relevant statute by tossing the murder weapon over a fence where it could be easily observed and recovered. View "State v. Hawkins" on Justia Law

In this divorce action, the trial court divided the parties' real and personal property, awarded custody of the children to the wife, and declined to award spousal support to the husband. The court of appeals (1) affirmed the trial court's custody determination and, except for the trial court's refusal to divide the wife's post-separation income, upheld the classification and division of the marital estate; but (2) reversed the trial court's judgment regarding spousal support and ordered the wife to to pay the husband transitional alimony in the amount of $2000 per month for thirty-six months. The Supreme Court (1) reversed that portion of the court of appeals' judgment awarding the husband transitional alimony, holding that the trial court did not abuse its discretion in declining to award the husband transitional alimony; and (2) affirmed in all other respects the intermediate appellate court's decision.View "Mayfield v. Mayfield " on Justia Law

Defendant pled guilty to reckless endangerment with a deadly weapon and theft of merchandise over five hundred dollars. The trial court sentenced Defendant as a Range II, multiple offender to three years on each count to be served concurrently. On appeal, Defendant argued that the trial court erred by failing to apply certain mitigating factors and by failing to grant probation or an alternative sentence. The court of criminal appeals, after declining to review the sentences because Defendant had failed to provide a transcript of the hearing on the guilty pleas, affirmed based upon a presumption that the evidence was sufficient to support the sentences. After granting an appeal because of conflicting opinions by the court of criminal appeals as to whether the absence of a transcript of a guilty plea submission hearing precludes appellate review on the merits, the Supreme Court ordered that the record be supplemented. The Court then affirmed the judgment of the trial court, holding that the record was adequate for a meaningful review of the sentences either with or without the transcript of the hearing on the guilty pleas, and Defendant was not entitled to relief. View "State v. Caudle" on Justia Law

A contract required payment of "fee residuals" from customers referred by BSG, LLC to Check Velocity, a company providing check re-presentment services. The contract provided that payment of fee residuals survived the termination of the agreement between the parties and continued until the "expiration of the Customer agreements as they may be renewed." Two agreements were executed between a referred customer and Check Velocity. The first agreement, which expired by its own terms, provided for check re-presentment services. The second agreement continued the re-presentment services required by the first agreement and added additional services. In addition, other terms of the first agreement were changed, including a choice of law provision. The Supreme Court held that the second agreement with additional services and changed terms was not a renewal of the first agreement, thus reversing the court of appeals and affirming the trial court's grant of summary judgment in favor of Check Velocity.View "BSG, LLC v. Check Velocity, Inc." on Justia Law

After the death of the president of the original corporate developer of a residential development, a successor developer purchased the property with the intent to continue to develop it. Homeowners filed suit, alleging the successor developer's new development plan violated restrictive covenants. The court of appeals remanded on the question of whether a general plan of development, or the plat for the subdivision, gave rise to certain implied restrictive covenants. Meanwhile, the homeowners' association amended its charter and the restrictive covenants, which the homeowners challenged. The trial court granted the successor developer summary judgment on all claims in both suits. The court of appeals remanded with directions to determine whether the amendments were reasonable and whether the plat supported the existence of implied restrictive covenants. The successor developer appealed, contending that Tennessee law did not support the court of appeals' reasonableness inquiry and that the plat provided no basis for the existence of implied restrictive covenants. The Supreme Court held that the amendments were properly adopted but found that there was no basis for implied restrictive covenants arising from a general plan of development or from the plat, thus vacating the portion of the court of appeals' judgment remanding the case.View "Hughes v. New Life Dev. Corp." on Justia Law

Shortly after the death of her daughter, Grandmother filed a petition seeking visitation with her granddaughter. The trial court denied Grandmother's request because she failed to prove the statutory grounds necessary to permit a court to order grandparental visitation over a parent's objection. After the decision became final, the General Assembly amended the burden of persuasion in the grandparental visitation statute. Without alleging new facts and relying solely on the change in the statutory burden of persuasion, Grandmother filed a second petition seeking visitation with her granddaughter. The trial court granted the child's father's motion to dismiss on the ground of res judicata. The court of appeals affirmed. The Supreme Court affirmed, holding that the intervening change in the burden of persuasion in the grandparental visitation statute did not provide an exception to the operation of the res judicata doctrine, and therefore, absent some material change in the facts, the doctrine of res judicata barred relitigation of Grandmother's petition for grandparental visitation.View "Jackson v. Smith" on Justia Law

The issue in this appeal was whether the statutory requirements for execution of an attested will prescribed by Tenn. Code Ann. 32-1-104(1) were satisfied when the decedent in this case (Decedent) failed to sign a two-page will but signed a one-page affidavit of attesting witnesses. The trial court held that the will was not properly executed. The court of appeals reversed, holding that Decedent's signature on the affidavit satisfied section 32-1-104 because Decedent intended his signature on the affidavit to be his signature on the will. The Supreme Court reversed the court of appeals and reinstated the judgment of the trial court, holding that Decedent's signature on the affidavit did not satisfy the statute requiring the testator's signature on a will.View "In re Estate of Chastain" on Justia Law