Justia Tennessee Supreme Court Opinion Summaries

Defendant was indicted on sixteen counts of animal cruelty for intentionally or knowingly failing to provide necessary food and care to horses on his farm. Defendant pleaded not guilty and filed an application for pretrial diversion, stating that he lacked a criminal history and claiming that the horses were sick when he received them. The assistant district attorney general denied the application, finding that the factors against granting pretrial diversion outweighed those in favor of granting pretrial diversion. Defendant filed a petition for writ of certiorari seeking judicial review. The trial court found no abuse of discretion, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding that the assistant district attorney general did not abuse his discretion in denying Defendant pretrial diversion. View "Stanton v. State" on Justia Law

Employer, a temporary staffing agency, assigned Employee to work temporarily at a manufacturing facility. Employee suffered a work-related injury during the assignment and reported the injury to Employer. At approximately the same time, the manufacturing facility ended Employee's assignment. Employer subsequently terminated Employee's employment and did not return Employee to work. The trial court awarded Employee workers' compensation benefits but capped the award at one and one-half times the medical impairment rating. The special workers' compensation appeals panel vacated the trial court's judgment and remanded for a determination of whether Employee had a meaningful return to work. The Supreme Court vacated the judgments of the lower courts, holding that because Employer neither returned Employee to work after his injury, nor offered him an opportunity to work, nor terminated his employment for misconduct, Employee's benefits award was governed by the statute authorizing benefits up to six times the medical impairment rating rather than the statute capping benefits at one and one-half times the medical impairment rating. Remanded. View "Britt v. Dyer's Employment Agency, Inc." on Justia Law

Oak Ridge FM, Inc. contractually agreed for Dick Broadcasting Company (DBC) to have a right of first refusal to purchase Oak Ridge's radio station assets. The agreement was assignable by DBC only with Oak Ridge's consent. DBC subsequently asked Oak Ridge to consent to the assignment of the right-of-first-refusal agreement, but Oak Ridge refused. Oak Ridge also refused to consent to the assignment of a time brokerage agreement and a consulting agreement, both of which lacked consent agreements. DBC sued Oak Ridge and others for breach of contract and violation of the implied covenant of good faith and fair dealing. The trial court granted summary judgment in favor of Defendants. The court of appeals vacated the trial court's judgment. The Supreme Court affirmed, holding (1) where parties have contracted to allow assignment of an agreement with the consent of the non-assigning party, and the agreement is silent regarding the anticipated standard of conduct in withholding consent, an implied covenant of good faith and fair dealing requires the non-assigning party to act with good faith and in a commercially reasonable manner in deciding whether to consent to the assignment; and (2) genuine issues of material fact remained in dispute in this case. View "Dick Broad. Co., Inc. of Tenn. v. Oak Ridge FM, Inc." on Justia Law

Employee was injured while in the course of scope of his employment through the actions of a third-party tortfeasor (Tortfeasor). Employee filed a claim for workers' compensation benefits and a lawsuit against Tortfeasor. Employer intervened in the lawsuit to protect its subrogation lien against any recovery from Tortfeasor. Employee settled the lawsuit with Tortfeasor and dismissed the case. Employer filed a motion to set the case for trial, asserting that it was entitled to a lien against the settlement proceeds for the cost of future medical benefits that may be paid on behalf of Employee. After initially setting the case for trial, the trial court dismissed for failure to state a claim. The court of appeals reversed and remanded, concluding that future medical expenses are not too speculative as a matter of law to be included in an employer's lien against the proceeds of a suit against a third-party tortfeasor. The Supreme Court reversed, holding that Employer failed to state a claim for which relief can be granted, as Employer's subrogation lien against the proceeds of the settlement did not extend to the cost of future medical benefits to which Employee may be entitled. View "Cooper v. Logistics Insight Corp." on Justia Law

Plaintiff was a tenured teacher who worked for Defendant, the Memphis City Schools Board of Education. After Plaintiff requested and was granted a substantial amount of sick leave but failed to return from that sick leave, Defendant dismissed Plaintiff without providing her with written charges or an opportunity for a hearing. Plaintiff filed a complaint alleging that her dismissal violated the Tennessee Teacher Tenure Act and her constitutional due process rights. The trial court granted Plaintiff's motion for partial summary judgment and awarded Plaintiff's reinstatement, back pay, compensatory damages for the actual harm she suffered, and attorney's fees. The court of appeals vacated the grant of summary judgment. The Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court, holding (1) although a tenured teacher's failure to return from sick leave may constitute cause for termination, there is no statute authorizing a board of education to deem it a constructive resignation or a forfeiture of tenure; and (2) accordingly, Defendant violated Plaintiff's rights under the Tenure Act and her constitutional due process rights. View "Thompson v. Memphis City Schs. Bd. of Educ." on Justia Law

Petitioner was sentenced to death in 1991 after pleading guilty to murder and rape. In 2010, Petitioner filed a petition seeking to reopen his post-conviction proceeding on the ground that he possessed new scientific evidence of his actual innocence. His evidence consisted of a newly-obtained I.Q. test score purporting to show he could not be executed because he was intellectually disabled. The trial court denied the petition, determining, as a matter of law, that Petitioner's I.Q. test score was not new scientific evidence of his actual innocence. The court of criminal appeals affirmed because the I.Q. test score did not amount to scientific evidence of actual innocence for the purpose of Tenn. Code Ann. 40-30-117(a)(2) and because Coleman v. State did not announce a new rule of constitutional law under section 40-30-117(a)(1). The Supreme Court affirmed, holding (1) the General Assembly, when it enacted section 40-30-117(a)(2), did not intend for the phrase "actually innocent of the offense" to include ineligibility for the death penalty because of intellectual disability; and (2) Coleman v. State does not establish a new rule of constitutional law that must be applied retroactively under section 40-30-117(a)(1). View "Keen v. State" on Justia Law

In 2000, an affidavit of complaint was issued charging "John Doe" with an aggravated rape that occurred in 1994. The affidavit led to the issuance of an arrest warrant. In 2008, law enforcement officers discovered that fingerprints taken from the scene of the crime matched those of Defendant. Later, police determined that the DNA profile of "John Doe" contained in the affidavit was that of Defendant, and a superseding indictment was issued in his name. Defendant was subsequently convicted of attempted aggravated rape. Defendant appealed, arguing that the "John Doe" warrant with the DNA profile was insufficient to identify Defendant and commence prosecution within the applicable statute of limitations. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) a criminal prosecution is commenced if, within the statute of limitations for a particular offense, a warrant is issued identifying the defendant by gender and his or her unique DNA profile; and (2) furthermore, a superseding indictment in the defendant's name provides the requisite notice of the charge. View "State v. Burdick" on Justia Law

Defendant was found guilty of one count of facilitation of aggravated burglary and two counts of theft of property. After finding the presence of one enhancement factor, the trial court imposed concurrent three-year sentences for each offense. The court of criminal appeals found the enhancement factor did not apply and reduced each of the sentences to two years. The Supreme Court reversed the sentence modification by the court of criminal appeals and reinstated the sentence imposed by the trial court, holding (1) a sentence imposed by a trial court should be upheld so long as it is within the appropriate sentencing range and is otherwise in compliance with the purposes and principles of the sentencing statute; and (2) notwithstanding the trial court's reliance on an erroneous enhancement factor in this case, its imposition of three-year sentences was supported by the reasons articulated in the record. View "State v. Bise" on Justia Law

An employee filed a request for assistance with the Tennessee Department of Labor after she was injured at her workplace. After approximately six months of inaction by the Department, the employee filed a complaint for workers' compensation benefits against her employer in the circuit court. The employer responded with a motion to dismiss asserting that the trial court lacked subject matter jurisdiction because the parties had not participated in the benefit review conference process. The trial judge did not dismiss the complaint but ordered the case to be held in abeyance pending further orders of he court. The Supreme Court reversed the judgment of the trial court and dismissed the employee's complaint with prejudice, holding that the trial court did not have subject matter jurisdiction of the case because the employee did not exhaust the benefit review conference process before filing suit as required by Tenn. Code Ann. 50-6-203. View "Chapman v. Davita, Inc." on Justia Law

Defendant, a crematory operator, hid hundreds of uncremated bodies on his property rather than perform cremations he was paid to do. When Plaintiffs, who had received what they thought to be their deceased son's cremains from Defendant's crematory, learned about the problems at the crematory, they discovered the body of their son was mishandled and not properly cremated. Plaintiffs sued Defendant for the alleged mishandling of their deceased son's body. Following a jury verdict for Plaintiffs, the trial court entered judgment against Defendant based on the intentional infliction of emotional distress claim but granted his motion for a judgment notwithstanding the verdict on Plaintiffs' Tennessee Consumer Protection Act (TCPA) and bailment claims. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not err in (1) holding Defendant liable for intentional infliction of emotional distress in the amount of the jury verdict; (2) instructing the jury that they were permitted to draw a negative inference resulting from Defendant's invocation of his Fifth Amendment privilege during questioning; and (3) dismissing the TCPA and bailment claims. View "Akers v. Prime Succession of Tenn., Inc." on Justia Law