Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of criminal appeals ruling that the restitution order at issue on appeal was not a final and appealable order under Tenn. R. App. P. 3, holding that a criminal restitution order is final and appealable when it directs a defendant to pay a set amount of restitution without payment terms.Defendant pleaded guilty to burglary and theft. As a condition of his probation, Defendant was ordered to pay restitution in the amount of $5,500 during his supervision. Defendant appealed the restitution order, but the court of criminal appeals dismissed the appeal for lack of jurisdiction, concluding that the restitution order was not a final order because it failed to include either payment terms or a payment schedule. The Supreme Court reversed and affirmed the trial court's judgment, holding (1) the restitution order resolved all issues and was a final order under Rule 3; and (2) the trial court did not err by ordering Defendant to pay $5,5000 in restitution over his two-and-a-half-year probationary period. View "State v. Cavin" on Justia Law

The Supreme Court held that a reimbursement cap imposed by the Tennessee Department of Finance and Administration's Division of TennCare, the state agency tasked with administering the federal Medicaid program in Tennessee, was a "rule" within the meaning of the Uniform Administrative Procedures Act that should have been promulgated through the notice-and-comment process.Emergency Medical Care Facilities, P.C., a corporation compromised of private healthcare professionals who provide emergency-department services to TennCare enrollees, brought this action against TennCare alleging that TennCare's decision to impose a $50 cap on the amount that Emergency Medical and other healthcare professionals could recover from TennCare for certain treatment provided to TennCare enrollees was a rule and that TennCare violated the Tennessee Uniform Administrative Procedures act (UAPA) by implementing the cap without rulemaking. The chancery court granted summary judgment in favor of Emergency Medical. The court of appeals reversed, concluding that the $50 cap fell within the so-called "internal-management exception" to the UAPA. The Supreme Court reversed, holding that the $50 cap was a rule under the UAPA and should have been promulgated through notice-and-comment rulemaking. View "Emergency Medical Care Facilities, P.C. v. Division of Tenncare" on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing claims of direct negligence against a defendant physician but allowing Plaintiff to proceed against the physician on a vicarious liability theory as the midwife's supervising physician, holding that the trial court properly declined to compel the defendant physician's testimony.By and through her next friend and mother (Plaintiff), a child born via cesarean section who suffered permanent brain damage and debilitating injuries, sued the doctor who delivered her and the midwife in charge of the birthing process. The trial court dismissed the claims of direct negligence against the physician but allowed Plaintiff to proceed on a vicarious liability theory against the physician as the midwife's supervising physician. A jury found in favor of Defendants. The court of appeals reversed in part, holding that the trial court committed reversible error in refusing to order the physician to opine on the midwife's performance outside of his presence. The Supreme Court reversed, holding that a defendant healthcare provider cannot be compelled to provide expert opinion testimony about a co-defendant healthcare provider's standard of care and/or deviation from that standard. View "Borngne ex rel. Hyter v. Chattanooga-Hamilton County Hospital Authority" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court terminating the parental rights of Parents, the parents of an infant (Markus) who suffered more than twenty rib fractures, holding that the evidence in the record did not clearly and convincingly show that Parents' failure to protect Markus from the non-accidental rib fractures was "knowing."Tenn. Code Ann. 37-1-102(b)(22)(A)(i) defines several child abuse as "knowing" failure to protect a child from abuse or neglect likely to cause serious injury or death. In the instant case, the trial court terminated Parents' parental rights on the ground of severe abuse. The court of appeals affirmed. The Supreme Court reversed, holding (1) the evidence did not clearly and convincingly show that both parents were aware of facts, circumstances, or information that would alert a reasonable parent to take affirmative action to protect the child and yet they failed to act; and (2) the trial court erred in terminating Mother's parental rights based on substantial noncompliance with the permanency plan. View "In re Markus E." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the order of the trial court denying Plaintiff's motion to alter or amend an order of voluntary dismissal, holding that there was no valid order of voluntary dismissal to alter or amend.Plaintiff initiated a healthcare liability action against a physician, a hospital, and two other defendants and then filed an amended complaint naming only the physician as a defendant. Thereafter, Plaintiff filed a notice of voluntary dismissal dismissing all defendants except the physician. The trial court entered an order of voluntary dismissal. The physician sought dismissal under the Governmental Tort Liability Act because the hospital was not a defendant. Plaintiff then filed his motion to alter or amend seeking to set aside the order voluntarily dismissing the hospital from the action. The trial court denied the motion, dismissed the hospital from the action with prejudice, and granted summary judgment for the physician. The court of appeals reversed. The Supreme Court reversed, holding (1) Plaintiff's notice of voluntary dismissal and the trial court's order of voluntary dismissal were of no legal effect because Plaintiff removed the hospital from the lawsuit when he filed his amended complaint; and (2) therefore, the trial court correctly denied Plaintiff's motion to alter or amend, albeit for different reasons. View "Ingram v. Gallagher" on Justia Law

The Supreme Court affirmed the opinion of the court of criminal appeals affirming Defendants' convictions of filing a lien without a reasonable basis and forgery of at least $250,000, holding that the evidence was sufficient to support Defendants' forgery convictions and to support sentencing Defendants' convictions for forgery as a Class A felony.The five defendants in this consolidated appeal were collectively convicted of 102 counts of filing a lien without a reasonable basis, a Class E felony, and 102 counts of forgery of at least $250,000, a Class A felony. Defendants appealed their forgery convictions, arguing, among other things, that their conduct did not fit within the statutory definition of forgery. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendants' forgery convictions under Tenn. Code Ann. 39-14-114(b)(1)(B); and (2) the evidence was sufficient to support the classifications of Defendants' forgery convictions as Class A felonies. View "State v. Lyons" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's convictions and reinstated the judgments of the trial court, holding that the intermediate court erred when it stated that an involuntary confession claim is "inextricably linked" to a Miranda waiver claim such that the two inquiries can be considered together.Defendant, a juvenile at the time of the offenses, was convicted of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. Defendant was sentenced to life in prison for the murder conviction. On appeal, the court of criminal appeals reversed the denial of Defendant's motion to suppress pretrial statement to detectives, concluding that the statement was not voluntary. The Supreme Court reversed, holding (1) Defendant's overall statement was voluntary, and his Miranda waiver was both knowing and voluntary; and (2) the evidence presented by the State was sufficient to support Defendant's conviction for premeditated first-degree murder. View "State v. McKinney" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing the trial court's dismissal of Plaintiff's complaint for malicious prosecution against his union, the local chapter, and several individuals associated with the union, holding that Plaintiff did not allege sufficient facts for a court to conclude that the dismissal of his criminal case was a favorable termination.Plaintiff brought this action alleging that the union's leadership accused him of misusing union funds after he publicly criticized the union's financial waste, leading to his indictment on two felony charges. The State successfully moved to retire the charges for one year, after which the charges were dismissed. The trial court dismissed Plaintiff's malicious prosecution claim on the basis that the retirement and dismissal of the criminal charges was not a favorable termination on the merits. The court of appeals reversed. The Supreme Court reversed, holding (1) Plaintiffs can pursue a claim for malicious prosecution only if an objective examination, limited to the documents disposing of the proceeding or the applicable procedural rules, indicates the termination of the underlying criminal proceeding reflects on the merits of the case and was due to the innocence of the accused; and (2) under this standard, Plaintiff did not allege sufficient facts to survive a motion to dismiss. View "Mynatt v. National Treasury Employees Union, Chapter 39" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this employment action, holding that a civil service merit board does not act arbitrarily or capriciously by declining to allow an employee who is challenging his termination for just cause to inquire about more lenient discipline imposed on other employees.Plaintiff, a Shelby County Fire Department employee, participated in an altercation involving a firearm at a political rally and was subsequently investigated. Due to the altercation and Plaintiff's dishonesty during the investigation, Plaintiff was fired. Plaintiff appealed, requesting that the Shelby County Civil Service Merit Board ask questions about discipline imposed on other fire department employees. The Board affirmed. The court of appeals reversed and remanded the case, ruling that the Board arbitrarily and unreasonably excluded questions about other discipline. The Supreme Court reversed, holding that the Board's decision to decline to consider evidence of discipline imposed on other employees was nor arbitrary or capricious. View "Moss v. Shelby County Civil Service Merit Bd." on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that the Tennessee Governmental Tort Liability Act, which removes immunity for certain injuries caused by the negligent acts of an employee, lifts immunity for grossly negligent and reckless employee actions in addition to merely negligent ones, holding that the Act's waiver of immunity for "negligent" acts includes only ordinary negligence, not gross negligence or recklessness.Steven Lawson hit a "rock embankment" after a mudslide washed away part of Highway 70 on Clinch Mountain in Hawkins County, flipped down the mountain, and died before help arrived. Plaintiff brought this wrongful death action action against Hawkins County, the Hawkins County Emergency Communications District and the Hawkins County Emergency Management Agency, alleging that Defendants' grossly negligent and reckless conduct caused Lawson's death. The trial court granted Defendants' motions to dismiss, concluding that the Act gave Defendants immunity from recklessness claims and that the public-duty doctrine barred any negligence claims. The court of appeals reversed. The Supreme Court reversed, holding that the court of appeals erred by holding that the Act allows a plaintiff to sue a governmental entity for employee conduct that exceeds mere negligence. View "Lawson v. Hawkins County" on Justia Law