Justia Tennessee Supreme Court Opinion Summaries

While on patrol, a police officer observed a pick-up truck parked in a shopping center lot. Because the truck's headlights were turned on, the officer stopped her patrol car directly behind the truck and activated her blue lights. The officer then approached the truck, observed a beer can in a cup holder inside, and found Defendant in the driver's seat with the keys in the ignition. Defendant was subsequently convicted for his fourth offense of driving under the influence. The court of criminal appeals reversed, holding (1) Defendant had been seized by the officer at the time the blue lights were activated; and (2) at the time of the seizure, the officer lacked either probable cause or reasonable suspicion to support an investigatory stop. The Supreme Court affirmed, holding (1) the activation of blue lights will not always qualify as a seizure; and (2) the totality of the circumstances in this instance established that the officer seized Defendant absent probable cause or reasonable suspicion and was not otherwise acting in a community caretaking role. View "State v. Moats" on Justia Law

Husband and Wife signed a contract to make mutual wills and then executed those wills. Soon after Husband's death, Wife executed a new will that was inconsistent with her previous will. Following Wife's death, the children of Husband's earlier marriage filed an action asserting, among other things, that their stepmother's last will was invalid because it breached the contract to prepare mutual wills and that the will prepared by their stepmother pursuant to the contract to make mutual wills should be admitted into probate rather than her last will. The trial court granted summary judgment to Husband's children, determining that the contract to make mutual wills was supported by adequate consideration and that, therefore, Wife's last will was null and void. The court of appeals affirmed. The Supreme Court affirmed, holding that Husband's children were entitled to judgment as a matter of law sustaining their challenge to the validity of Wife's will because, as a matter of law, the contract to make mutual wills was supported by adequate consideration. View "In re Estate of Brown" on Justia Law

After a jury trial, Petitioner was convicted of especially aggravated kidnapping, aggravated assault, especially aggravated robbery, and other robbery charges. The Supreme Court denied Petitioner's appeal, and the U.S. Supreme Court denied Petitioner's petition for writ of certiorari. Petitioner filed a petition for postconviction relief after the statutory deadline had passed because his former attorney provided him the wrong deadline date and failed to give Petitioner his legal files until after the actual deadline had passed. The criminal court dismissed the petition as untimely. The court of criminal appeals affirmed. The Supreme Court reversed and remanded the case to the trial court so Petitioner could pursue his petition for postconviction relief, holding (1) the facts of this case reflected that Petitioner was effectively abandoned by his appellate attorney after his petition for writ of certiorari was filed in the U.S. Supreme Court; (2) this abandonment impeded Petitioner's otherwise diligent efforts to file a timely postconviction petition; and (3) therefore, the statute of limitations should be tolled. View "Whitehead v. State" on Justia Law

Since their divorce in 2001, Father and Mother litigated their rights and responsibilities relative to their three children, including a prior appeal in which Father succeeded in overturning a voluntary termination of his parental rights. On remand, the trial court declined to terminate Father's parental rights, finding that Mother and Stepfather had not proven either proffered ground for abandonment by clear and convincing evidence. The court of appeals reversed, concluding that the evidence clearly and convincingly established abandonment by both willful failure to visit and willful failure to support. The Supreme Court affirmed in part and reversed in part, holding that Mother and Stepfather established by clear and convincing evidence abandonment by willful failure to visit but failed to establish willful failure to support. Remanded for consideration of whether termination was in the best interests of the children. View "In re Adoption of Angela E." on Justia Law

This case arose out of the death of Decedent and the ensuing dispute between his two sons from a previous marriage and Linda Carraway, whom he married two weeks before his death. Decedent's sons (Sons) challenged the validity of their father's marriage to Carraway (Wife) and the validity of the lost will that Wife sought to have established. Wife claimed she was the sole beneficiary of Decedent's estate pursuant to the terms of his will. After a jury trial, the jury found in favor of Sons. The court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) Wife waived her argument that Sons lacked standing to contest the validity of her marriage to their father; but (2) the trial court erred in allowing into evidence testimony regarding Wife's real property holdings and her late mother's will, and the error was not harmless. View "In re Estate of Smallman" on Justia Law

When the nursing staff at the assisted living facility where Mable Farrar lived did not give Farrar an over-the-counter medicine for constipation as often as her doctor had prescribed, Farrar became constipated. Thereafter, Farrar's doctor notified the staff at the facility to give Farrar three to four enemas each day. A facility nurse gave Farrar only two enemas in three days. Farrar subsequently died of a perforated colon. Farrar's daughters filed a wrongful death action against the nurse who gave the enemas, the director of nursing at the facility, the owner of the facility, and the facility's management company. The jury found the management company fifty percent at fault based on its failure to provide sufficient personnel at the facility. The court of appeals reversed the jury verdict against the management company, finding that there was no material evidence that staffing deficiencies proximately caused Farrar's death. The Supreme Court reversed the court of appeals and reinstated the jury verdict, holding that material evidence supported the jury's finding that the management company's conduct was a substantial factor in causing Farrar's death. Remanded for review of the award of punitive damages. View "Wilson v. Americare Sys., Inc." on Justia Law

Employee injured his back while working for Employer. Employee and the Department of Labor and Workforce Development (Department) agreed upon a settlement that provided for a lump sum payment to Employer for his injuries. The settlement and SD-1 form were signed by Employee and both parties' attorneys. Two years later, Employee filed a petition to set aside the settlement. The trial court granted Employee's petition. The Special Workers' Compensation Appeals Panel vacated the trial court's judgment on a procedural issue, finding the SD-1 form was not "fully completed." The Supreme Court reversed the judgments of the Panel and of the trial court and dismissed Employee's petition, holding (1) when the Department approves a settlement, it implicitly approves the accompanying SD-1 form, and a court has no authority to set the settlement aside based on its independent finding that the SD-1 form was not "fully completed"; and (2) the evidence preponderated against the trial court's finding that Employee was not represented by counsel, and the court erred in granting relief based on Tenn. R. Civ. P. 60.02(5) as well as its inherent authority. View "Furlough v. Spherion Atlantic Workforce, LLC" on Justia Law

Mother and Father entered into a martial dissolution agreement and parenting plan for their two minor children. Mother subsequently pleaded guilty to the attempted second degree murder of Father and was sentenced to twelve years incarceration. Mother and Father entered into an amended parenting plan that provided for the resumption of the original parenting plan after Mother's release from prison. Father remarried while Mother was incarcerated, and Father and Stepmother filed a petition for termination of Mother's parental rights and a petition for adoption by Stepmother. The trial court denied the petition after amending its original order, concluding that termination of Mother's parental rights was not in the best interests of the children. The court of appeals reinstated the trial court's original order terminating Mother's parental rights. The Supreme Court reversed the court of appeals and reinstated the amended order of the trial court, holding that Father and Stepmother failed to prove by clear and convincing evidence that termination of Mother's parental rights was in the best interests of the children. View "In re Taylor B.W." on Justia Law

Petitioner was convicted of premeditated first degree murder, especially aggravated robbery, and setting fire to person property. Petitioner subsequently filed a petition for post-conviction relief based partly on numerous instances of his trial counsel's ineffective assistance. The post-conviction court dismissed the petition. The court of criminal appeals, however, reversed Petitioner's convictions and remanded for a new trial, determining that Petitioner's trial counsel had been ineffective with regard to limitations placed on the ability of a defense expert to testify that Petitioner's mental condition rendered him unable to premeditate. The Supreme Court (1) reversed the judgment of the court of criminal appeals and affirmed the judgment of the post-conviction court on this issue, holding that Petitioner was not entitled to relief based on the manner in which his trial counsel dealt with the limitations placed of the defense's expert witness; and (2) reversed the judgment of the lower courts denying Defendant's claim relating to trial counsel's failure to object to the requirement that Petitioner wear a stun belt during the trial and remanded that issue for a new hearing, as the record did not permit the reviewing court to determine whether trial counsel was deficient with regard to this issue. View "Mobley v. State" on Justia Law

Defendant was convicted in three separate trials of three sets of execution-style murders, of seven persons total. Defendant faced seven death sentences. Defendant elected not to seek a new trial in any of these cases. Subsequently, Defendant's sister filed a "next friend" petition in each of the murder cases, requesting the courts to declare Defendant incompetent, thereby enabling her to pursue post-conviction relief on Defendant's behalf. Each court denied the petitions, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial courts employed the correct legal standard for determining whether Defendant possessed the mental capacity to rationally forego seeking post-conviction relief; (2) Defendant's sister failed to prove that Defendant lacked the capacity to make rational decisions regarding the pursuit of post-conviction relief; and (3) in all future cases, Tennessee's court should employ the mental competency standard of Tenn. Sup. Ct. R. 28, 11(B) to address the issue of a prisoner's competency to pursue post-conviction relief. View "Reid v. State" on Justia Law