Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's convictions, holding that the trial court committed reversible error by allowing impeachment evidence of a material defense witness without sufficient evidence, and the error was not harmless.After a jury trial, Defendant was convicted of attempted second-degree murder and unlawful employment of a firearm. The court of criminal appeals affirmed, holding, as relevant to this appeal, that Defendant's right to a speedy trial had not been violated and that the trial court did not commit reversible error in allowing improper impeachment of a defense witness. The Supreme Court reversed, holding (1) Defendant was not denied a speedy trial; but (2) the trial court's error in allowing improper impeachment evidence was reversible error. View "State v. Moon" on Justia Law

In this appeal concerning the revocation of Defendant's probation the Supreme Court affirmed the court of criminal appeals' decision affirming the judgment of the trial court revoking Defendant's probation and ordering him to serve the balance of his sentence, holding that a probation revocation proceeding ultimately involves a two-step inquiry.At issue was whether revocation proceedings are a one-step or two-step process and the appropriate appellate standard of review to be used in reviewing such determinations. The Supreme Court held (1) a probation revocation proceeding involves a two-step process; and (2) if the trial court has properly placed its findings on the record, the standard of review for probation revocations is abuse of discretion with a presumption of reasonableness. View "State v. Dagnan" on Justia Law

The Supreme Court reversed the judgments of the court of appeals and the trial court concluding that the Health Care Liability Act, Tenn. Code Ann. 29-26-101 to -122, did not apply to Plaintiffs' medical battery and intentional misrepresentation claims, holding that Plaintiffs' claims fell within the definition of a "healthcare liability action" under the Act.Plaintiffs sued a doctor and his medical practice alleging medical battery and intentional misrepresentation. Defendants filed a motion to dismiss on the grounds that Plaintiffs did not comply with the Act's pre-suit notice and filing requirements. The trial court agreed, ruling that Defendants' misrepresentations were made before they rendered any health care services and therefore did not relate to the provision of health care services. The court of appeals affirmed. The Supreme Court reversed, holding that the Act applied to Plaintiffs' claims. View "Cooper v. Mandy" on Justia Law

The Supreme Court affirmed the dismissal of Melissa Kampmeyer's loss of consortium claim brought after her husband, Steven Kampmeyer, was injured in an accident, holding that Tenn. Code Ann. 9-8-402(a)(1) requires claimants to give written notice of their claim to the Division of Claims and Risk Management as a condition precedent to recovery.Steven was injured when his car collided with a Tennessee state vehicle parked in the roadway. Steven gave written notice of his claim to the Tennessee Division of Claims and Risk Management, which transferred the claim to the Tennessee Claims Commission. Steven and Melissa then filed a complaint with the Claims Commission. The complaint contained Melissa's loss of consortium claim, which was not in the written notice Steven gave to the Division of Claims and Risk Management. The Claims Commission dismissed Melissa's loss of consortium claim as time-barred. The Supreme Court affirmed, holding that because Melissa did not give written notice of her claim to the Division of Claims and Risk Management within the one-year statute of limitations, her loss of consortium claim was time-barred. View "Kampmeyer v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of premeditated murder, first-degree felony murder, and other crimes and his sentence of death but reversed the portion of the judgment of the court of criminal appeals vacating the application of the felony murder aggravating circumstance, holding that the trial court properly convicted and sentenced Defendant.The court of criminal appeals affirmed Defendant's convictions and sentences but vacated the application of the felony murder aggravating circumstance as to the felony murder conviction. The Supreme Court reversed the portion of the intermediate court's judgment that vacated the application of the felony murder aggravating circumstances to the felony murder conviction, holding (1) the trial court did not err by either removing or failing to remove prospective jurors for cause during individual voir dire based on their view on the death penalty; (2) there was sufficient evidence to support Defendant's convictions; (3) there was no error in the trial court's evidentiary rulings; and (4) Defendant's challenges to his death sentence were unavailing. View "State v. Miller" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's conviction of premeditated first-degree murder, holding that the evidence was sufficient to support the conviction and that the trial court did not reversibly err in admitting evidence related to gang membership.After a jury trial, Defendant was convicted of premeditated first-degree murder. The court of criminal appeals reversed and remanded the case for a new trial, holding (1) the evidence of premeditation was legally insufficient, and (2) the trial court abused its discretion in admitting certain pieces of evidence related to gang membership. The Supreme Court reversed, holding (1) the evidence was legally sufficient to sustain the conviction; and (2) there was no reversible error with respect to the trial court's admission of gang-related evidence or any other evidentiary issue raised by Defendant. View "State v. Reynolds" on Justia Law

The Supreme Court affirmed the judgment of the court of workers' compensation claims determining that Employee's workplace injury did not arise primarily out of and in the course and scope of his employment and granting summary judgment for Employer, holding that the court of workers' compensation claims property granted summary judgment for Employer.Employee was painting the exterior of a house a house while working for Employer on a windy day when he took a break from painting. At one point, he used a portable restroom, not obtained by Employer, located on the street and was struck by a dead tree that had fallen. Employer denied Employee workers' compensation, finding that Employee's injury resulted from an "act of God" and did not arise primarily out of his employment. The Supreme Court affirmed, holding that the court of workers' compensation claims properly determined that Employee's injuries did not arise primarily out of his employment. View "Rosasco v. West Knoxville Painters, LLC" on Justia Law

The Supreme Court held that the economic loss doctrine applies when a fraud claim seeks recovery of only economic losses and is premised solely on nondisclosures or misrepresentations about the quality of goods that are the subject of a contract between sophisticated commercial parties.Plaintiff sued Defendants alleging breach of express and implied warranties, breach of contract, negligent misrepresentation, fraud, and a Tennessee Consumer Protection Act (TCPA) claim. The trial court granted Defendants summary judgment on the breach of contract, breach of warranty, and negligent misrepresentation claims. After a trial, the jury returned a verdict for Plaintiff on the fraud and TCPA claims and awarded compensatory and punitive damages. The trial court entered judgment on the jury's verdicts and awarded Plaintiff attorney's fees. On appeal, the court of appeals ruled in favor of Defendants and against Plaintiff, concluding that the economic loss doctrine barred the fraud claim and that the claim under the TCPA was barred as a matter of law. The Supreme Court set aside Plaintiff's award of attorney's fees and costs based on the TCPA and otherwise affirmed, holding that because Plaintiff's TCPA claim failed as a matter of law, the award of attorney's fees and costs under the TCPA could not stand. View "Milan Supply Chain Solutions, Inc. v. Navistar, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the decision of the trial court enjoining Defendant's proposal to build a structure for the operation of a retail business, holding that restrictive covenants executed and recorded by the developers of a subdivision after they had sold the parties' lots did not apply to Defendant's property.The developers in this case platted a subdivision and sold the majority of lots with time-limited restrictions against non-residential use stated in the deeds that conveyed the lots. The developers then recorded a declaration of non-time-limited restrictive covenants, including a restriction against non-residential use, purporting to apply to all lots in the subdivision. Years later, Defendant purchased lots and proposed a commercial use of the property. Plaintiffs brought a declaratory judgment action seeking to enforce the restriction against non-residential use. The trial court enjoined Defendant from constructing any retail business or commercial enterprise on his property. The Supreme Court reversed, holding (1) the developers lacked the authority to impose the declaration's restrictions as a servitude upon Defendant's property because they did not own the property when they executed and recorded those restrictive covenants; and (2) the developers' re-acquisition and re-sale of some of Defendant's lots after the recording of the declaration did not retroactively restrict Defendant's property through the declaration. View "Phillips v. Hatfield" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment dismissing Plaintiff's second lawsuit, holding that the doctrine of res judicata did not bar the lawsuit.Plaintiff originally filed suit against Defendant in the Circuit Court for Shelby County, but, unbeknownst to the parties, the trial court sua sponte dismissed the lawsuit for failure to prosecute. Ten months later, Plaintiff learned of the dismissal and filed a motion to set aside the dismissal. The trial court denied the motion but entered an order stating that the dismissal did not bar Plaintiff from refiling its lawsuit. When Plaintiff subsequently refiled its lawsuit, the trial court granted Defendant's motion to dismiss based on the doctrine of res judicata. The court of appeals affirmed. The Supreme Court reversed the decision of the court of appeals and vacated the judgment of the trial court, holding that the involuntary dismissal of the first suit for failure to prosecute did not operate as an adjudication on the merits, and therefore, the present lawsuit was not barred by the doctrine of res judicata. View "Regions Bank v. Prager" on Justia Law