Justia Tennessee Supreme Court Opinion Summaries

In two cases consolidated for oral argument, defendants entered guilty pleas to one count in their respective indictments in exchange for dismissal of other counts. In both cases, the trial court denied their subsequent requests for expungement of the dismissed charges. Both defendants filed petitions for writ of certiorari. The court of criminal appeals reversed both cases and remanded for entry of orders requiring the requested partial expungement. The Supreme Court granted the State's applications for permission to appeal and ordered supplemental briefing on the issue of whether the court of criminal appeals lacked subject matter jurisdiction. The Court affirmed, holding (1) the procedural requirements for petitions for writ of certiorari set forth in Tenn. Code Ann. 27-8-106 do not apply in criminal cases, and (2) a conviction for one count in an indictment does not preclude expungement of the records relating to a dismissed charge in a separate count. View "State v. L.W." on Justia Law

At issue in this case was the applicable standard that courts should use in determining whether a medical expert is qualified to testify as an expert witness in a medical malpractice case. Donna Shipley filed a medical malpractice action against two doctors and a hospital, alleging various claims for medical negligence. The trial court granted the hospital and one doctor summary judgment. After disqualifying Shipley's medical experts, the trial court granted summary judgment to the remaining defendant, Dr. Williams, and dismissed Shipley's case. The court of appeals upheld the trial court's decision to disqualify Shipley's medical experts but reversed the grant of summary judgment on Shipley's negligence claims. The Supreme Court (1) reversed the trial court's judgment disqualifying Shipley's medical experts; (2) reversed the judgment of the court of appeals in part and reinstated summary judgment in Dr. Williams' favor on one of Shipley's negligence claims; and (3) vacated the trial court's order granting summary judgment on Shipley's remaining claims. Remanded. View "Shipley v. Williams" on Justia Law

While Alicia Howell worked on an assembly production line at Nissan North America, she was diagnosed with bilateral carpal tunnel syndrome. After surgery, Howell and Nissan settled Howell's workers' compensation claim for her carpal tunnel injuries. When Howell attempted to return to work, she was told she would be returning to the fast-paced assembly line. Howell resigned and was hired at minimum wage for a temporary staffing agency. Howell then filed a petition for reconsideration of her earlier settlement. The trial court held that Howell was eligible for reconsideration of her workers' compensation benefits because she did not have a meaningful return to work and awarded her a twenty-five percent permanent partial disability rating to each upper extremity. The Special Workers' Compensation Appeals Panel reversed. The Supreme Court reversed the judgment of the appeals panel and reinstated the judgment of the trial court, holding (1) the appeals panel erred in holding that Howell had a meaningful return to work and her decision to resign rather than returning to work was unreasonable, and (2) the trial court's award was not excessive. View "Howell v. Nissan N. Am., Inc." on Justia Law

Defendant was convicted of, inter alia, four counts of aggravated rape. The trial court sentenced Defendant to forty years on each of the aggravated rape convictions and structured service of the sentences to result in an effective term of eighty years. The judgment orders designated Defendant a "Multiple 35% Range 2" offender but did not designate Defendant as a "Multiple Rapist." The court of criminal appeals affirmed Defendant's convictions and sentence. Defendant then filed a pro se petition for writ of habeas corpus on the basis that the trial court did not have authority to sentence him as a "Multiple 35% Range 2" offender. The habeas corpus court denied relief. The court of criminal appeals affirmed. The Supreme Court granted habeas corpus relief, holding that Defendant's four sentences for his four aggravated rape convictions were illegal because each of the judgment orders indicated that Defendant was eligible for early release on parole (by the designation "Multiple 35% Range 2" offender) instead of indicating that he must serve his entire sentence (by the designation "Multiple Rapist") in direct contravention of Tenn. Code Ann. 39-13-523. Remanded for the entry of amended judgment orders reflecting Defendant's status as a "Multiple Rapist." View "Cantrell v. Easterling" on Justia Law

Employee injured his shoulder while working for Employer. After Employee returned to work, he filed a claim for workers' compensation benefits. Employee and Employer settled Employee's claim. The settlement stated that the award of vocational disability benefits to which the parties agreed was not based on the medical impairment rating of either the treating physician or Employee's independent medical examiner. After Employee was laid off, he sought reconsideration of his benefits. The chancery court awarded additional permanent disability benefits based on an impairment rating computed from the percentage of permanent partial disability reflected in the settlement. Employer appealed. At issue was whether the chancery court erred in declining to apply any of three impairment ratings assigned by physicians after the original settlement. The Supreme Court affirmed, holding (1) a court's reconsideration of a workers' compensation award is limited to a determination of additional permanent partial disability based on the employee's impairment rating at the time of the initial award or settlement, and therefore, the chancery court properly computed the medical impairment rating; and (2) the award was not excessive. View "Lazar v. J.W. Aluminum" on Justia Law

After Pam Webb, who was employed by the Nashville Area Habitat for Humanity, was fired, Webb filed a complaint alleging retaliatory discharge. Habitat filed a motion to dismiss Webb's complaint for failure to state a claim upon which relief can be granted pursuant to Tenn. R. Civ. P. 12.02(6). Webb filed an amended complaint, and Habitat responded by filing an amended Rule 12.02(6) motion to dismiss. The trial court granted Habitat's motion and dismissed the amended complaint on all claims. The court of appeals vacated the trial court's judgment, holding that the amended complaint sufficiently stated a cause of action for retaliatory discharge. The Supreme Court granted review. At issue was the proper standard for Tennessee courts to apply in ruling on a Rule 12.02(6) motion to dismiss and whether the Court should adopt the pleading standard set forth in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, which retired the notice pleading regime recognized in Conley v. Gibson in favor of a new plausibility pleading standard. The Supreme Court declined to adopt the new Twombly/Iqbal plausibility pleading standard and affirmed the judgment of the court of appeals. View "Webb v. Nashville Area Habitat for Humanity, Inc." on Justia Law

After a local vendor of termite control services discovered that two of its competitors had overbilled Knox County for services, the vendor presented a report of its findings to county officials. When the County delayed taking remedial action, the vendor filed a qui tam suit pursuant to Tenn. Code Ann. 4-18-104(c) against the companies in chancery court. The County joined the vendor's lawsuit and eventually settled with the defendants. When the qui tam plaintiff sought a share of the County's settlement with one of the vendors, the County asserted that the qui tam plaintiff was not eligible to receive any of the settlement proceeds. The trial court held that the qui tam plaintiff was an "original source" for the purpose of section 4-18-104(c) and, therefore, was entitled to receive twenty-eight percent of the settlement proceeds, or $71,546. The court of appeals affirmed but remanded the case to redetermine the value of the settlement proceeds. The Supreme Court affirmed the decisions of both the trial court and the court of appeals that the qui tam plaintiff was an "original source" and, therefore, was eligible to receive a portion of the proceeds from the County's settlement with one of the vendors. View "Knox County ex rel. Environmental Termite & Pest Control, Inc. v. Arrow Exterminators, Inc." on Justia Law

Employee injured her right shoulder in the course of her employment with Employer. Employee received medical treatment, during which time she continued to work for Employer. Employee filed a complaint in chancery court seeking workers' compensation benefits from her Employer. At trial, the parties contested the extent of Employee's anatomical impairment and permanent disability. The medical evidence at trial consisted of the testimony of two physicians, and through their testimony, the parties introduced Employee's medical records generated by other treating physicians. The physicians assigned varying degrees of impairment to the body as whole. The trial court eventually chose the evaluating physician's impairment, who assigned a seventeen percent impairment, and awarded Employee 25.5 percent permanent partial disability to the body as a whole. Employer appealed, arguing that the evaluating physician's rating did not comply with the American Medical Association Guides and that the award was therefore excessive. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by accepting the evaluating physician's impairment rating as the basis of the disability award. View "Morris v. Jackson Clinic Prof'l Assoc." on Justia Law

After Employee sustained an injury, he filed a worker's compensation action against Employer. The result was a court-approved workers' compensation settlement. Employee's authorized treating physician later recommended medical treatment. After Employer's utilization review provider denied approval of the proposed treatment, Employer filed a motion for an independent medical examination, pursuant to Tenn. Code Ann. 50-6-204(d)(1), which is required if reasonable. The trial court found Employer's request to be unreasonable and denied the motion. On appeal, the Special Workers' Compensation Appeals Panel reversed the judgment of the trial court, holding (1) Employer had good faith reasonable basis for questioning both the causation and the necessity of the proposed treatment and for filing a motion for a physical examination of Employee; and (2) the trial court abused its discretion in finding that Employer's request for a medical examination of Employee was unreasonable. Remanded. View "Irons v. K & K Trucking, Inc." on Justia Law

Plaintiff James Crowley obtained a judgment in the amount of $14,500 against defendant Wendy Thomas in the general sessions court. Thomas appealed to the circuit court. In the circuit court, Crowley amended his complaint to add his wife as an additional plaintiff and an additional cause of action and to seek additional damages in the amount of $125,000. Shortly before trial, Thomas filed a notice dismissing her appeal. The circuit court dismissed the appeal and affirmed the judgment of the general sessions court. The Crowleys moved the circuit court to vacate, alter, or amend its dismissal of Thomas's appeal, which the circuit court denied. The Crowleys appealed, and the court of appeals affirmed. On appeal, the Supreme Court held that the circuit court properly dismissed the defendant's appeal and affirmed the general sessions court judgment. To preserve the plaintiff's original cause of action after such dismissal, the plaintiff must perfect an appeal to the circuit court as prescribed by Tenn. Code Ann. 27-5-108. Affirmed. View "Crowley v. Thomas" on Justia Law