Justia Civil Procedure Opinion Summaries

The plaintiffs alleged that the defendants committed fraud related to property rights. The defendants, through their business, REO Holdings, LLC, bought properties at tax sales and used redemption rights to obtain titles, some of which were later found to be fraudulent. The case involved four specific properties where the defendants allegedly used misrepresentation and forged documents to redeem and sell the properties at a profit.The Chancery Court for Davidson County initially dismissed the plaintiffs' claims for unjust enrichment and misappropriation of redemption rights, finding that unjust enrichment required a voluntary conferral of a benefit and that Tennessee law did not recognize conversion of intangible property rights. The court also denied class certification. After a jury trial, the plaintiffs moved for a new trial, arguing that the evidence preponderated against the jury’s verdict. The trial court denied the motion, and the Court of Appeals reversed, finding that the trial court misconceived its role as thirteenth juror.The Supreme Court of Tennessee reviewed the case and held that remand for the trial court to fulfill its role as thirteenth juror is an appropriate remedy when a civil trial court misconceives that role or applies an incorrect standard. The court also held that a claim for unjust enrichment does not require a voluntary conferral of a benefit, overruling previous case law to the extent it held otherwise. Finally, the court affirmed that Tennessee law does not recognize a claim for misappropriation or conversion of a right of redemption. The decision of the Court of Appeals was affirmed in part and reversed in part, and the case was remanded for further proceedings consistent with the opinion. View "Family Trust Services LLC v. Green Wise Homes LLC" on Justia Law

The case involves a defamation claim brought by Bill Charles, a real estate professional and president of the homeowners' association of the Durham Farms community in Hendersonville, Tennessee, against Donna McQueen, a resident of the same community. McQueen had posted a critical review of Charles on Google, accusing him of using misleading tactics to deceive home buyers. Charles filed a defamation and false light claim against McQueen, who sought dismissal of the claims under the Tennessee Public Participation Act, arguing that Charles could not establish a prima facie case for his claims because he could not prove actual malice.The trial court agreed with McQueen and dismissed the claims. The Court of Appeals reversed in part, agreeing that Charles had to prove actual malice for his false light claim but holding that Charles was not a public figure and therefore did not need to prove actual malice for his defamation claim.The Supreme Court of Tennessee disagreed with the Court of Appeals, holding that Charles is a limited-purpose public figure given his voluntary and prominent role in a controversy concerning changes to the Durham Farms development plan. The court further held that Charles failed to establish a prima facie case of actual malice. The court also rejected Charles’s argument that McQueen waived her request for appellate attorney’s fees by failing to list it as an issue in her Court of Appeals brief. The court reversed the Court of Appeals in part and affirmed in part, remanding the case for further proceedings. View "Charles v. McQueen" on Justia Law

This case involves a conservatorship dispute over Susan Davis Malone. Two attorneys involved in the case filed two motions requesting the trial judge to recuse himself. The first recusal motion was denied and affirmed on appeal. The second recusal motion was also denied. The attorneys then filed a second petition for recusal appeal, arguing that trial court orders entered after the Court of Appeals issued its opinion in the first recusal appeal, but before the mandate issued, are void for lack of subject matter jurisdiction.The Court of Appeals agreed with the attorneys and held that the orders were void. The counterpetitioners and co-conservators then filed an accelerated application for permission to appeal in the Supreme Court of Tennessee.The Supreme Court of Tennessee granted the application and reversed the judgment of the Court of Appeals. The court held that the stay imposed by the Court of Appeals in the first recusal appeal did not divest the trial court of subject matter jurisdiction over the case. The court also held that the attorneys waived any other argument that orders entered by the trial court should be vacated because they were entered prior to issuance of the mandate. The case was remanded for further proceedings consistent with this decision. View "In Re Conservatorship of Malone" on Justia Law

The case involves a slip and fall incident at a Trader Joe's grocery store in Nashville, Tennessee. The plaintiff, Melissa Binns, alleged that she slipped and fell due to the negligence of an employee who was stocking shelves in a disorganized manner, causing a package of tofu to fall and spill liquid on the floor. Binns filed a complaint against Trader Joe's East, Inc., alleging premises liability, negligent training, and negligent supervision. Trader Joe's sought to dismiss the negligent training and supervision claims, arguing that these claims should be dismissed when asserted concurrently with a premises liability claim and that the plaintiff's direct negligence claims were no longer viable due to the defendant admitting it was vicariously liable for the conduct of its employee.The trial court rejected both of Trader Joe's arguments and denied its motion for partial judgment on the pleadings. The court granted permission for an interlocutory appeal, which was denied by the Court of Appeals. Trader Joe's then appealed to the Supreme Court of Tennessee, which granted review.The Supreme Court of Tennessee held that the preemption rule, which would dismiss direct negligence claims when a defendant admits vicarious liability, is incompatible with Tennessee's system of comparative fault and declined to adopt it. The court also declined to adopt the rule proposed by Trader Joe's that "negligent activity" claims cannot be asserted alongside premises liability claims. As a result, the court affirmed the trial court's order denying Trader Joe's motion for partial judgment on the pleadings and remanded the case back to the trial court for further proceedings. View "Binns v. Trader Joe's East, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the conclusion of the trial court that Plaintiff failed to establish Defendant's requisite minimum contacts with Tennessee, and thus the court lacked personal jurisdiction over Defendant with respect to Plaintiff's suit, holding that the trial court correctly dismissed Plaintiff's complaint.Plaintiff, a Tennessee resident, hired Defendant, an Alabama corporation with its principal place of business in Alabama, to build a house on a parcel of land in Alabama. Upon becoming dissatisfied with the quality and expense of the construction work Plaintiff filed suit in the Davidson County Chancery Court. The trial court granted Defendant's motion to dismiss for lack of jurisdiction, concluding that Defendant's contacts with Tennessee were minor and attenuated. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff failed to establish a prima facie case of the minimum contacts necessary for a Tennessee court to exercise specific personal jurisdiction over Defendant. View "Baskin v. Pierce & Allred Construction, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's dismissal of Plaintiffs' action seeking a declaratory judgment concerning the rights and obligations of the parties under a 2001 contract, holding that the court of appeals erred in concluding that dismissal was appropriate on the grounds that the complaint was barred by the doctrine of res judicata.In a previously filed action, Plaintiffs sought similar relief, but the case was dismissed for failure to exhaust administrative remedies. In the instant case, the trial court granted Defendants' motions to dismiss, finding that Plaintiffs lacked standing. The court of appeals affirmed on other grounds, concluding that res judicata barred the complaint and, as such, declined to address the standing issue. The Supreme Court reversed, holding that dismissal of the previous case did not constitute an adjudication on the merits for purposes of res judicata. The Court then remanded the case to the court of appeals for consideration of the standing issue. View "Elvis Presley Enterprises, Inc. v. City of Memphis" 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 clarified the procedure circuit courts must follow when an original defendant in general sessions court appeals an adverse general sessions judgment to circuit court but then fails to appear for the de novo circuit court trial to prosecute his appeal, holding that, in the instant case, the circuit court erred in dismissing Appellant's appeal.When Appellant failed to appear in circuit court to prosecute his appeal from an adverse general sessions court judgment the circuit court dismissed the appeal and remanded this case to the general sessions court for execution of the judgment. The court of appeals reversed the circuit court's order that it lacked subject matter jurisdiction. The Supreme Court affirmed, holding (1) under Tenn. Code Ann. 27-5-106 and -107, the circuit court should have entered a default judgment against Appellant in the amount of the general sessions judgment, subject to execution in the circuit court; and (2) after the circuit court dismissed the appeal and remanded to the general sessions court, the circuit court had subject matter jurisdiction to grant Defendant's motion to set aside its prior order. View "Ken Smith Auto Parts v. Thomas" on Justia Law

The Supreme Court affirmed the ruling of the trial court that documents containing communications between a corporation’s legal counsel and a property management property were protected under the attorney-client privilege, holding that the attorney-client privilege applied to the documents in this case.After acquiring commercial properties, the corporation filed unlawful detainer actions against the properties’ tenants. The tenants sought documents from the property management company that managed the corporation’s properties, but the corporation and property management company objected to producing the documents. The trial court concluded that the property management was an agent of the corporation, and therefore, the attorney-client privilege applied. The Supreme Court affirmed on different grounds, holding (1) the attorney-client privilege extends to communications between an entity’s legal counsel and a third-party non employee of the entity if the non employee is the functional equivalent of the entity’s employee; (2) the property management company in this case was the functional equivalent of the corporation’s employee; and (3) the communications related to the subject matter of counsel’s representation of the corporation and were made with the intention that they would be kept confidential. View "Dialysis Clinic, Inc. v. Medley" on Justia Law

In this case alleging health care liability claims, the trial court erred by allowing Plaintiff to amend her complaint after the expiration of the statute of limitations to substitute as a defendant a health care provider to which Plaintiff had not sent pre-suit notice.The Supreme Court reversed the decisions of the trial court and court of appeals, holding that Plaintiff did not comply with the mandatory pre-suit notice provision of the Tennessee Health Care Liability Act, Tenn. Code Ann. 29-26-121(a)(1), because she did not give written pre-suit notice of the potential claim to the health care provider she later sought to substitute as a defendant after the expiration of the statute of limitations. View "Runions v. Jackson-Madison County General Hospital District" on Justia Law