Justia Tennessee Supreme Court Opinion Summaries

The Supreme Court held that a claim for wrongful termination of employment could not be asserted under the Teacher Tenure Act, Tenn. Code Ann. 49-5-501 to -515, by classifying a tenured teacher's resignation as a constructive discharge rather than a voluntary quit.After Plaintiff, a tenured teacher, quit her teaching position she sued for wrongful termination under the Teacher Tenure Act, alleging that she was constructively discharged. The amended complaint also asserted other claims. The trial court granted summary judgment against Plaintiff. The appellate court reversed the trial court's dismissal of Plaintiff's wrongful discharge claim under the Act, concluding that the doctrine of constructive discharge could give rise to a wrongful termination claim under the Act. The court of appeals otherwise affirmed the trial court. The Supreme Court reversed in part, holding (1) constructive discharge is not applicable to wrongful termination claims under the Act; and (2) the lower courts properly dismissed Plaintiff's remaining claims. View "Lemon v. Williamson County Schools" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment to the manufacturers of certain equipment (Equipment Defendants) in this product liability action, holding that, on the facts and applicable law, the Equipment Defendants had no duty to warn of the dangers associated with the post-sale integration of asbestos-containing materials manufactured and sold by others.Plaintiffs asserted claims against the Equipment Defendants under the Tennessee Products Liability Act, Tenn. Code Ann. 29-28-101 through -108, for failing to warn of the dangers of exposure to asbestos-containing products that the Equipment Defendants did not manufacture or sell. The trial court granted summary judgment in favor of the Equipment Defendants. The court of appeals reversed, holding that the Equipment Defendants owed a common law duty to warn about the post-sale integration of asbestos-containing products manufactured and sold by others. The Supreme Court reversed, holding that, under the language of the Act, the Equipment Defendants could not be held liable for injuries resulting from products that they did not make, distribute, or sell. View "Coffman v. Armstrong International, Inc." on Justia Law

The Supreme Court held that the seven District Attorneys General who sued several drug companies under the Tennessee Drug Dealer Liability Act lacked standing and that the two Baby Doe plaintiffs who sued under the Act and alleged facts showing that the drug companies knowingly participated in the illegal drug market by facilitating the marketing or distribution of opioids stated a claim against the drug companies under the Act.The District Attorneys and the Baby Doe plaintiffs brought this action alleging that the defendant drug companies knowingly participated in the illegal drug market by intentionally flooding East Tennessee communities with prescription opioid medications. The Baby Doe plaintiffs alleged that they were harmed by exposure to opioids in utero and the District Attorneys claimed that the opioid epidemic had damaged the communities in their districts. The trial court dismissed the case, ruling that the Act did not apply. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the District Attorneys lacked standing to bring an action under the Act as individual plaintiffs; and (2) the Baby Doe plaintiffs stated a claim against the drug companies based on allegations of intentional and purposeful participation in the illegal opioid market. View "Effler v. Purdue Pharma L.P." on Justia Law

The Supreme Court reinstated the trial court's judgment terminating Mother's parental rights on the basis of the statutory factor enumerated in Tenn. Code Ann. 36-1-113(g)(14), holding that the statute is ambiguous and that In re Ayden S., No. M2017-01185-COA-R3- PT, 2018 WL 2447044, 7 (Tenn. Ct. App. May 31, 2018), is overruled.Section 36-1-113(g)(14) requires a person seeking termination of parental rights to prove by clear and convincing evidence that a "parent or guardian has failed to manifest, by act or omission, an ability and willingness to personally assume legal and physical custody or financial responsibility of the child." In In re Ayden S., the court of appeals interpreted this language as requiring proof that a parent was both unable and unwilling personally to assume legal and physical custody or financial responsibility of a child. In In re Amynn K., No. E2017-01866-COA- R3-PT, 2018 WL 3058280, 14 (Tenn. Ct. App. June 20, 2018), the court of appeals construed the statute as requiring proof that a parent was either unable or unwilling to personally assume legal and physical custody or financial responsibility of a child. The Supreme Court held that the In re Amynn K. interpretation best effectuated legislative intent and thus reversed. View "In re Neveah M." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for an insurance agent on Plaintiffs' claim that the insurance agent negligently failed to procure excess uninsured motorist coverage in accordance with Plaintiffs' instructions, holding that Tenn. Code Ann. 56-7-135(b) applies to create a rebuttable presumption in actions against an insurance agent for negligent failure to procure an insurance policy as directed.In granting summary judgment for the insurance agent, the trial court concluded that Plaintiffs had failed to rebut the statutory presumption that they had accepted the provided coverage, which did not include excess uninsured motorist coverage. The court of appeals reversed, determining that the rebuttable presumption in section 56-7-135(b) does not apply to actions against an insurance agent. The Supreme Court reversed, holding (1) the rebuttable presumption articulated in section 56-7-135(b) applies to actions against an insurance agent by insureds under the insurance policy for negligent failure to procure an insurance policy as directed; and (2) Plaintiffs failed to rebut the statutory presumption in this case. View "Parveen v. ACG South Insurance Agency, LLC" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's denial of Defendant's motion for recusal, holding that, for the reasons provided today in State v. Griffin, __ S.W.3d __ (Tenn. 2020), Defendant failed to establish that there was a reasonable basis to question the trial judge's impartiality.In this case, one of three decided today involving a trial judge who previously served as a deputy district attorney general in Knox County at the time the defendants in each case were indicted by the Knox County Grand Jury, Defendant moved for recusal, arguing that the trial judge previously had supervisory authority over his case as Deputy District Attorney General. The trial judge denied the motion for recusal, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that, as in Griffin, Defendant failed to establish that the trial judge's supervisory responsibilities in his role as Deputy District Attorney General were personal or substantial in that case. View "State v. Clark" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's denial of Defendant's motion for recusal, holding that, for the reasons provided today in State v. Griffin, __ S.W.3d __ (Tenn. 2020), Defendant failed to establish that there was a reasonable basis to question the trial judge's impartiality.In this case, one of three decided today involving a trial judge who previously served as a deputy district attorney general in Knox County at the time the defendants in each case were indicted by the Knox County Grand Jury, Defendant moved for recusal, arguing that the trial judge previously had supervisory authority over his case as Deputy District Attorney General. The trial judge denied the motion for recusal, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that, as in Griffin, Defendant failed to establish that the trial judge's supervisory responsibilities in his role as Deputy District Attorney General were personal or substantial in that case. View "State v. Styles" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's decision to deny Defendants' motion for recusal on the grounds that the trial judge had supervisory authority over their cases as Deputy District Attorney General, holding that the trial judge appropriately denied the motion to recuse in this case.The trial judge here served as a deputy district attorney general in Knox County at the time Defendants were indicted by the Knox County Grand Jury. The trial judge was subsequently appointed to serve as a trial judge in Knox County Criminal Court and assigned to Defendant's cases. Defendants moved for recusal. The trial judge denied the motions, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that the trial judge did not err in denying the motion for recusal because a person of ordinary prudence in the judge's position, knowing all the facts known to the trial judge, would not find a reasonable basis for questioning the judge's impartiality. View "State v. Griffin" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the chancery court dismissing this complaint against a Texas company for lack of personal jurisdiction, holding that the exercise of specific personal jurisdiction was constitutionally permissible.The Texas company contracted with a Tennessee civil engineering company for services related to the potential construction of a railcar repair facility in Texas. When the Texas company failed to pay in full, the Tennessee company filed a breach of contract action in Tennessee. The chancery court dismissed the complaint, concluding that the Texas company lacked the minimum contacts necessary for the exercise of personal jurisdiction and that requiring the Texas company to litigate in Tennessee would be unreasonable and unfair. The court of appeals reversed. The Supreme Court affirmed, holding (1) the Tennessee company established a prima facie case for the valid exercise of personal jurisdiction over the Texas company; and (2) the exercise of jurisdiction was fair and reasonable. View "Crouch Railway Consulting, LLC v. LS Energy Fabrication, LLC" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals to remand this case and reinstated the post-conviction court's denial of Petitioner's petition for post-conviction relief, holding that the Court of Criminal Appeals was without authority under the Post-Conviction Procedure Act to remand this case for consideration of an issue that was not raised by either party.Petitioner pled guilty to attempted first-degree murder and especially aggravated robbery. Petitioner was sentenced to seventeen years' imprisonment to be served concurrently with a previously imposed federal sentence and consecutive to a state sentence. Petitioner later filed a petition for post-conviction relief. The post-conviction court denied the petition. The Court of Criminal Appeals affirmed the denial of the petition but remanded the case for an evidentiary hearing to consider whether Petitioner was advised of the consequences of entering a guilty plea based upon the agreement that his state sentence be served concurrently with his prior federal sentence. The Supreme Court reversed, holding that because Petitioner did not raise the concurrent sentencing issue in his post-conviction petition, during his hearing, or on appeal, the issue was waived. View "Holland v. State" on Justia Law