Justia Tennessee Supreme Court Opinion Summaries

A victim of alleged child sexual abuse purportedly perpetrated by one of the priests of the Catholic Diocese of Memphis in the 1970s filed suit against the Bishop of the Diocese, seeking monetary damages. The Diocese moved to dismiss the complaint, arguing that the ecclesiastical abstention doctrine deprived state courts of subject mater jurisdiction and that the victim's claims were barred by the statute of limitations. The trial court denied the Diocese's motion. The court of appeals held (1) the ecclesiastical abstention doctrine barred state courts from considering the victim's negligent hiring and retention claims but not the negligent supervision claims; and (2) the statute of limitations had run on the victim's claims. The Supreme Court reversed in part, holding (1) the state courts had subject matter jurisdiction over the victim's claims; and (2) the victim's claims were not barred by the statute of limitations. Remanded. View "Redwing v. Catholic Bishop for the Diocese of Memphis" on Justia Law

Plaintiffs filed a personal injury suit against The Royal Group. The Royal Group filed an answer alleging the comparative fault of Aaron Rents. Plaintiffs then filed an amended complaint adding Aaron Rents as a defendant. The one-year statute of limitations applicable to Plaintiffs' cause of action, however, had expired before The Royal Group filed its answer naming Aaron Rents. As a result, Plaintiffs filed their amended complaint within ninety days of The Royal Group's answer, relying on Tenn. Code Ann. 20-1-119. Aaron Rents thereafter alleged fault against Fulmarque. Plaintiffs subsequently filed a second amended complaint, naming Fulmarque as a defendant. The trial court eventually granted summary judgment in favor of Fulmarque, concluding (1) the action was barred by the statute of limitations, and (2) the ninety-day window provided by section 20-1-119 was not triggered by Aaron Rents' answer alleging comparative fault against Fulmarque. The court of appeals reversed. The Supreme Court reversed the court of appeals and reinstated the judgment of the trial court, holding that section 20-1-119 does not afford successive ninety-day windows during which a plaintiff may file an amended complaint naming a nonparty defendant as a comparative tort-feasor. View "Mills v. Fulmarque, Inc." on Justia Law

Employee fell and struck both knees on a concrete landing in the course of his employment with Employer. Employee's left knee required surgery and his right knee received limited medical treatment. The treating physician assigned eight percent permanent impairment to the left leg. Employee's evaluating physician assigned thirteen percent impairment to the left leg and twenty percent impairment to the right leg. The trial court adopted the evaluating physician's opinions and awarded fifty percent permanent partial disability to both legs. The Special Workers' Compensation Appeals Panel affirmed, holding that the trial court did not err (1) by finding that Employee sustained a permanent injury to the right knee; (2) by adopting the impairment rating of the evaluating physician for Employee's right and left knee injury; and (3) in awarding fifty percent permanent partial disability to both legs, where Employee had significant activity restrictions as a result of the injury. View "Hale v. Ins. Co. of the State of Pa." on Justia Law

Employee, a truck driver, was injured in the course and scope of his employment when his vehicle left the road and turned over. Employer denied Employee's claim for workers' compensation benefits, contending that the accident and resulting injuries were the direct result of Employee's willful violation of Employer's safety rules. The trial court found that Employee had willfully and intentionally disregarded the safety rules and entered judgment for Employer. Employee appealed, contending that the trial court erred because the evidence did not establish the perverseness of his conduct, a necessary element of the misconduct affirmative defense. The Supreme Court affirmed, holding that the trial court did not err in finding that Employee willfully and intentionally violated Employer's safety rules, where Employee did not give a credible explanation regarding his failure to comply with the rules, and Employer offered strong proof of its strong emphasis on compliance with the safety rules. View "Keith v. Western Express, Inc." on Justia Law

The Supreme Court granted an appeal in these two consolidated cases to clarify the remedy that should be applied when there is an abuse of prosecutorial discretion in the denial of an application for pretrial diversion. In each case, the prosecutor denied the defendant's petition for pretrial diversion, and the trial court ruled there was no abuse of discretion. The court of criminal appeals decided in each case that there was an abuse of discretion because the prosecutor failed to weigh all the relevant factors in reaching his decision to deny pretrial diversion to the defendant and remanded the case to the trial court to order the prosecutor to approve the defendant's pretrial diversion application. The Supreme Court reversed, holding that when a prosecutor has abused his discretion by failing to consider and weigh all the relevant pretrial diversion factors or by considering and relying upon an irrelevant factor, the appropriate remedy is to vacate the prosecutor's ruling and remand to the prosecutor to consider and weigh all of the relevant factors. Remanded. View "State v. Thomason" on Justia Law

The Supreme Court granted an appeal in these two consolidated cases to clarify the remedy that should be applied when there is an abuse of prosecutorial discretion in the denial of an application for pretrial diversion. In each case, the prosecutor denied the defendant's petition for pretrial diversion, and the trial court ruled there was no abuse of discretion. The court of criminal appeals decided in each case that there was an abuse of discretion because the prosecutor failed to weigh all the relevant factors in reaching his decision to deny pretrial diversion to the defendant and remanded the case to the trial court to order the prosecutor to approve the defendant's pretrial diversion application. The Supreme Court reversed, holding that when a prosecutor has abused his discretion by failing to consider and weigh all the relevant pretrial diversion factors or by considering and relying upon an irrelevant factor, the appropriate remedy is to vacate the prosecutor's ruling and remand to the prosecutor to consider and weigh all of the relevant factors. Remanded. View "State v. Richardson" on Justia Law

This appeal involved the status of six children who had been in the custody of their biological mother. After one of the children was severely injured, the juvenile court determined that all six children were dependent and neglected and were the victims of severe child abuse. The circuit court and court of appeals affirmed. The mother filed a Tenn. R. App. P. 11 application for permission to appeal, taking issue with the sufficiency of the evidence. In its response, the Department of Children's Services conceded that the evidence was not sufficient to support a finding that the five uninjured children were victims of severe child abuse. The Supreme Court granted an appeal and held (1) the injured child was a victim of severe child abuse; (2) the evidence did not support the lower courts' conclusion that the remaining five uninjured children were also victims of severe child abuse; and (3) the evidence demonstrated clearly and convincingly that all six children were dependent and neglected. View "In re DeAndre C." on Justia Law

Plaintiff filed suit in the general sessions court seeking damages sustained in an automobile accident. Plaintiff also notified her uninsured/underinsured motorist carrier of her suit. After deciding that her damages exceeded the general sessions court's jurisdictional limit, Plaintiff requested the general sessions court to dismiss her suit. The court dismissed Plaintiff's suit, and Plaintiff perfected a de novo appeal to the circuit court. After Plaintiff accepted Defendant's settlement offer, Plaintiff's insurance carrier moved to dismiss Plaintiff's underinsured motorist claim because her settlement with Defendant equaled the amount of damages she had sought in general sessions court. The trial court granted the insurance company's motion because Plaintiff failed to file an amended complaint increasing the amount of her damages claim. The court of appeals affirmed. The Supreme Court affirmed, holding that because Plaintiff failed to amend to increase the amount of damages beyond those specified in her general sessions warrant, the trial court did not err by dismissing her claims against the insurance company. View "Brown v. Roland" on Justia Law

Petitioner filed petitions for post-conviction relief challenging his 1985 conviction and life sentence for the first degree felony murder of John Pierce, his 1989 conviction for the first degree felony murder of Novella Webb, and his 1995 death sentence for the Webb murder. The Supreme Court (1) affirmed Smith's conviction and sentence for the Pierce murder, holding that Smith's post-conviction claims were barred by the statute of limitations; (2) affirmed Smith's conviction for the Webb murder, holding that Smith did not demonstrate he suffered prejudice resulting from his counsel's ineffective assistance in failing to adequately question the potential jurors during voir dire; (3) vacated Smith's death sentence, holding that Smith's counsel provided ineffective assistance in failing to adequately investigate and present evidence supporting his motion to recuse the judge at his resentencing hearing, which resulted in a denial of Smith's due process right to a fair trial before an impartial tribunal; and (4) held that Smith was entitled to a new hearing on the question of whether he was intellectually disabled at the time of the Webb murder because the lower courts applied an incorrect legal standard in determining Smith's functional IQ. Remanded. View "Smith v. State" on Justia Law

At issue in this appeal was the proper procedure for obtaining judicial review of a local legislative body's land use decision under the "Jackson Law," Tenn. Code Ann. 68-211-701 to -707. The opponents of a coal ash landfill, approved by the Cumberland County Commission, filed a petition for a statutory writ of certiorari in the chancery court seeking judicial review of the Commission's decision. The trial court dismissed the petition because it was not verified as required by Tenn. Code Ann. 27-8-106. The court of appeals affirmed. The Supreme Court granted Petitioners' application for permission to appeal because the Jackson Law did not specifically define the procedure for seeking judicial review of a local legislative body's decisions. The Court reversed, holding (1) a local legislative body's decision under the Jackson Law may be challenged either by a petition for a statutory writ of certiorari or by a complaint for declaratory judgment, and (2) the lower courts erred by failing to treat the statutory petition for writ of certiorari as a complaint for declaratory judgment. Remanded. View "Brundage v. Cumberland County" on Justia Law