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Supreme Court Opinions - 1st Quarter 2002

The following Opinions are available for download:


Cases posted the week of 03/25/2002
State v. Timothy McKinney - W1999-00844-SC-DDT-DD View
State v. Timothy McKinney - W1999-00844-SC-DDT-DD (Concur/Dissent) View
Shelby County - The defendant, Timothy McKinney, was convicted of premeditated first degree murder and attempted second degree murder. The jury imposed a death sentence for the first degree murder after finding that evidence of an aggravating circumstance, i.e., the defendant was previously convicted of a felony whose statutory elements involved the use of violence to the person, outweighed evidence of mitigating circumstances beyond a reasonable doubt. The trial judge imposed a sentence of twelve (12) years for the attempted second degree murder, to run consecutively to the death sentence. After the Court of Criminal Appeals affirmed the convictions and the sentences, the case was automatically docketed in this Court. We entered an order specifying six issues for oral argument, and we now hold as follows: (1) the trial court did not commit error by denying the defendant's motion to introduce expert testimony on the issue of eyewitness identifications; (2) the jury's verdict form was sufficiently clear to demonstrate that the jury found the prior violent felony aggravating circumstance relied upon by the prosecution; (3) the evidence was sufficient to sustain the prior violent felony aggravating circumstance found by the jury; (4) the trial court's refusal to allow defense counsel to refer to evidence from the guilt phase of the trial during his closing argument in the sentencing phase of the trial did not affect the jury's determination to the prejudice of the defendant and was harmless error; (5) the trial court did not commit error in admitting victim impact evidence during the sentencing phase; and (6) the sentence of death was neither arbitrary nor disproportionate. We also conclude that the evidence was sufficient to support the jury's findings that the prior violent felony aggravating circumstance had been established beyond a reasonable doubt and that it outweighed evidence of mitigating factors beyond a reasonable doubt. Finally, we agree with the Court of Criminal Appeals' conclusions with respect to the remaining issues, the relevant portions of which are included in the appendix to this opinion. Accordingly, we affirm the judgment of the Court of Criminal Appeals.

Robert Davis, et al v. Wilson County - M2000-00785-SC-R11-CV View
We granted this appeal to determine whether county employees had a vested interest after retirement in health care benefits provided under resolutions passed by the Wilson County Commission. The chancellor found that the appellants had a vested interest in health care benefits because they were county employees who met the requirement of ten years of service and eight years of continuous service with Wilson County under a 1992 resolution. The Court of Appeals reversed the chancellor's judgment, concluding that the health care benefits were welfare benefits in which the appellants did not have a vested interest. After reviewing the record and applicable authority, we hold that the health care benefits were welfare benefits that did not vest automatically and that there was no clear and express language in the resolutions that the health care benefits were intended to vest or could not be terminated. We therefore affirm the Court of Appeals' judgment.

Ralph Richards v. Liberty Mutual Ins. Co. - M2000-01255-SC-WCM-CV View
Coffee County - We granted review in this workers' compensation case to determine whether the Special Workers' Compensation Appeals Panel erred in concluding that the evidence preponderated against the trial court's finding that the employee's injury did not arise out of and in the course of his employment. After reviewing the record and applicable authority, we conclude that the evidence did not preponderate against the trial court's finding that the employee's injury did not arise out of and in the course of his employment. We therefore reject the Panel's findings and conclusions and affirm the judgment of the trial court.

Connie Givens v. Ed Mullikin, Admin. ad litem for Larry McElwaney - W1999-01783-SC-R11-CV View
Shelby County - The principal issue in this case is whether an insurance carrier and an insured may be held vicariously liable for the alleged tortious actions of an attorney hired to defend the insured. The trial court held that the plaintiff's complaint stated a claim of vicarious liability against the defendant insured and his insurance carrier for abuse of process, inducement to breach express and implied contracts of confidentiality, inducement to breach a confidential relationship, and invasion of privacy. The Court of Appeals affirmed the trial court's ruling with respect to the vicarious liability issue, though it dismissed the claims for inducement to breach a confidential relationship and invasion of privacy. The defendants then appealed to this Court, and we now hold that an insurer and an insured may be held vicariously liable for the tortious acts or omissions of an attorney hired to defend the insured, if the attorney's tortious actions were directed, commanded, or knowingly authorized by the insurer or by the insured. We further hold that the complaint in this case states a claim of vicarious liability against the insurer alone for abuse of process. The judgment of the Court of Appeals is affirmed in part and reversed in part.

Trau-Med of America, Inc. d/b/a Bellevue Clinic v. AllState Ins. Co. - W1999-01524-SC-R11-CV View
Shelby County - The plaintiff, a medical clinic, filed an action against the defendants alleging, among other things, tortious interference with business relationships and civil conspiracy. The defendants filed a motion to dismiss, which the trial court granted. The Court of Appeals reversed the trial court's dismissal of these claims, finding that the facts alleged in the complaint were sufficient to state claims upon which relief could be granted. This case is now before us to determine whether the trial court should have granted the defendant's motion to dismiss. We hold that the complaint in this case alleges sufficient facts to state a cause of action for tortious interference with business relationships. However, we dismiss the plaintiff's claim of civil conspiracy for failure to satisfy the plurality requirement necessary to establish an actionable conspiracy claim. Consequently, we affirm in part and reverse in part the judgment of the Court of Appeals and remand this case to the trial court for further proceedings consistent with this opinion.

Heirs of Neil Ellis v. Estate of Virgie Ellis - M1999-00897-SC-R11-CV View
Rutherford County - The issue in this case is whether property held in a tenancy by the entirety is subject to the 120-hour survival rule contained in section 31-3-120 of the Tennessee Uniform Simultaneous Death Act. Three days after her husband's death, Mrs. Ellis died of unrelated natural causes, and her will was admitted to probate. The husband's heirs sought to intervene in the probate proceeding, claiming that because Mrs. Ellis did not survive her husband for 120 hours, section 31-3-120 deems both to have died "simultaneously." Consequently, they argued, Tennessee Code Annotated section 31-3-104 authorized them to seek a one-half interest in the entireties property. The trial court denied the motion to intervene, and the Court of Appeals affirmed. On appeal to this Court, we hold that section 31-3-120 does not require one spouse to survive the other by 120 hours in order to obtain fee simple title to property formerly held by the entirety. We also hold that the General Assembly, in enacting section 31-3-120, did not intend to define the term "simultaneously" in section 31-3-104 as meaning "within 120 hours." Instead, we conclude that the legislature intended that this term should continue to receive its ordinary construction, meaning "at the same time." The judgment of the Court of Appeals is affirmed.


Cases posted the week of 03/18/2002
Exxon Corp. v. Metro Govt. of Nashville & Davidson County - M2000-0061-SC-R11-CV View
We granted permission to appeal in this case to determine whether the Court of Appeals erred in defining the phrase "on that same location" as it is used in Tenn. Code Ann. § 57-5-109 to mean anywhere within the boundary lines of the property. We hold that such a definition, when considered in pari materia with the Nashville and Davidson County Metropolitan Code, broadens the scope of this statutory grandfather provision. Accordingly, we reverse the judgment of the Court of Appeals and affirm the judgment of the trial court.

State v. Alvin Taylor - M1999-02566-SC-R11-CD View
The sole issue in this appeal is whether Article I, Section 16 of the Tennessee Constitution or the Eighth Amendment of the United States Constitution is violated by Tenn. Code Ann. § 55-50-504(a)(2), a statute which provides a minimum fine, for second offense driving on a revoked license, but which fails to provide a maximum fine for the offense. We conclude that the statute is not facially unconstitutional under either the state or the federal constitution. However, fines imposed in specific cases under such statutes are subject to being challenged as excessive. When such a challenge is made, however, courts should first apply the principles of the Criminal Sentencing Reform Act to determine whether the fine is excessive before analyzing the constitutional validity of the fine. We conclude that the $27,500 fine imposed by the jury in this case is excessive under the principles of the Criminal Sentencing Reform Act. Accordingly, we modify the fine to the statutory minimum of $3,000. As modified, this fine does not contravene the state and federal constitutional provisions prohibiting excessive fines. Accordingly, we reverse that part of the judgment of the Court of Criminal Appeals holding Tenn. Code Ann. § 55-50-504(a)(2) unconstitutional.

William Dixon v. Flora Holland - M1999-02494-SC-R11-PC & Dixon v. Campbell - M1999-02122-SC-R11-CV View
Davidson County - We granted review in these consolidated cases to determine (1) whether William Andrew Dixon's sentence under Tenn. Code Ann. § 39-2603 (1975) is void and thus subject to habeas corpus relief; and (2) whether Tenn. Code Ann. § 41-21-236(c) (1997) applies to Dixon's sentence. We hold that Dixon's sentence is void and grant habeas corpus relief. We further hold that Dixon is entitled to any sentence reduction credits earned from 1988 until 1998. Our grant of habeas corpus relief pretermits the remaining issues raised by Dixon. Accordingly, the judgment of the Court of Criminal Appeals is reversed, and the case is remanded to the criminal court for proceedings consistent with this opinion.


Cases posted the week of 03/11/2002
State v. Sean Imfeld - E2000-00094-SC-R11-CD View
Knox County - The defendant entered guilty pleas to five counts of aggravated assault and was sentenced to three years for each conviction. The trial court ordered three of the sentences for aggravated assault to be served consecutively, for an effective sentence of nine years. The Court of Criminal Appeals affirmed. We granted permission to appeal to address three issues: (1) whether the trial court properly enhanced the defendant's sentences for aggravated assault on the basis that the offenses involved more than one victim, Tenn. Code Ann. § 40-35-114(3) (1997 & Supp. 2001); (2) whether the trial court properly enhanced the defendant's sentences on the basis that the crimes were committed under circumstances where the potential for bodily injury to a victim was great, id. § 40-35-114(16); and (3) whether the trial court properly imposed consecutive sentences on the basis that the defendant was a dangerous offender, id. § 40-35-115(b)(4). After reviewing the record and applicable authority, we conclude that the lower courts erred in applying the "multiple victims" and "potential bodily injury to a victim" enhancement factors, see id. §§ 40-35-114(3) and -114(16), but that a reduction in the length of the sentences is not warranted because several other valid enhancement factors were supported by the record. We also conclude that the trial court's imposition of consecutive sentences on the basis that the defendant was a dangerous offender was supported by the record. See id. § 40-35-115(b)(4). We therefore affirm the judgment of the Court of Criminal Appeals.

Ernest Frye v. Blue Ridge Neuroscience Center - E2000-02155-SC-R11-CV View
Sullivan County - We granted this appeal to determine whether process issued upon a second complaint satisfies Rule 3 of the Tennessee Rules of Civil Procedure when the plaintiff failed to serve process on the original complaint. After careful consideration of the Tennessee Rules of Civil Procedure and applicable case law, we hold that a plaintiff may rely upon the initial filing date to satisfy a statute of limitations if that plaintiff, having failed to issue or serve process within thirty days of filing the complaint, continues the action by issuing new process on the original complaint as required by Rule 3. In addition, a plaintiff may request a voluntary dismissal within the one-year time period under Rule 3, without having served process, and still rely on the original date of commencement to satisfy a statute of limitations if the plaintiff serves a copy of the Notice of Voluntary Dismissal and the complaint on the defendant as required by Rule 41.01. Because the plaintiff in this case failed to comply with either Rule 3 or Rule 41.01, the plaintiff may not rely on the filing date of the original complaint for purposes of satisfying the applicable one-year statute of limitations. Accordingly, the judgment of the Court of Appeals granting the defendants summary judgment is affirmed.


Cases posted the week of 02/18/2002
Robert Mannery vs. Wal-Mart Distribution Center - E2000-01930-SC-WCM-CV View
Greene County - The dispositive issue in this workers' compensation appeal is factual: whether the right inguinal hernia for which the plaintiff claims recovery existed prior to the work-related accident that occurred on April 24, 1998. If the hernia existed prior to the accident, recovery is barred by Tenn. Code Ann. § 50-6-212(a)(5) which provides that an employee must prove that the "hernia or rupture did not exist prior to the accident for which compensation is claimed." The trial court found that the hernia did not exist prior to the work-related accident, concluded that the plaintiff had a compensable workers compensation claim, and awarded the plaintiff twenty-one percent permanent partial disability to the body as a whole. The Special Workers' Compensation Appeals Panel affirmed the decision of the trial court. We granted the defendant's motion for review and now affirm the decision of the trial court and the Special Workers' Compensation Appeals Panel.

Woodlawn Memorial Park, Inc. vs. Roger Keith - M2000-00612-SC-WCM-CV View
Davidson County - In this workers' compensation appeal, an employee was allegedly injured in the course and scope of her employment. While purportedly seeking medical treatment for these injuries, she contracted an infection and died. The employer filed suit in the Davidson County Chancery Court claiming that no compensable injury occurred and that the employee used the excuse of an injury to seek prescription drugs for her addiction. The trial court held for the employer and later granted the employer's motion for discretionary costs. The Special Workers' Compensation Appeals Panel reversed, finding that a preponderance of the evidence established that a work-related injury did occur and that the employee died as a result of seeking treatment for those injuries. We then granted the employer's application for full court review and hold that the trial court's findings are supported by a preponderance of the evidence. We also hold that the trial court did not abuse its discretion in awarding discretionary costs to the employer. The judgment of the Davidson County Chancery Court is affirmed.

Daniel Barge vs. Earl and Vera Sadler - M1999-01923-SC-R11-CV View
Humphreys County - Daniel B. Barge III filed a petition seeking to condemn a portion of Earl and Vera Sadler's property for use as an easement for access to his landlocked property. The trial court found that Barge already enjoyed an easement by implication across John Sonday's property; thus, he could not show, as required by the condemnation statute, that he had no other access to a public road. The Court of Appeals reversed the trial court's judgment and held that the Sadler property was the proper location for an easement to Barge's land. The Sadlers make two contentions on appeal: (1) that the Court of Appeals erred in designating the property to be burdened by the easement; and (2) that Barge failed to join all adjoining landowners as indispensable parties defendant. We hold that the jury of view, not the intermediate appellate court, is the proper body to determine the location of an easement granted pursuant to Tenn. Code Ann. § 54-14-101(a)(1) (Supp 2000). We further hold that those owning property upon which an easement could practically be constructed should be named as parties defendant. Therefore, we affirm the judgment of the Court of Appeals holding that the property is landlocked and reverse the judgment locating the easement; in all other respects, the judgment is affirmed. The cause is remanded to the trial court for the appointment of a jury of view and other proceedings consistent with this opinion.

Tammy Kline et al vs. Daniel Eyrich - E2000-01890-SC-R11-CV View
Knox County - The primary issue in this case is whether a trial court may use the common fund doctrine in a wrongful death action to spread attorneys' fees equitably among the surviving beneficiaries of the action. The trial court consolidated two wrongful death actions, which were brought by the surviving spouse and children of the decedent, and it gave the surviving spouse control of the consolidated action. After the suit was settled, the trial court awarded the surviving spouse's attorney one-third of the settlement proceeds as a fee. On appeal, the children argued that the trial court improperly awarded fees to the surviving spouse's attorney from their share of the settlement because they possessed no contract with that attorney. A majority of the Court of Appeals held that although the award of fees could be proper under the common fund doctrine, the case should be remanded to resolve factual ambiguities in the record. We granted permission to appeal and hold that a trial court has the discretion to apply the common fund doctrine to the proceeds of a wrongful death action, thereby obliging the beneficiaries of that action to pay a reasonable fee to the attorney procuring the judgment or settlement. We also hold that the record contains no evidence showing that the trial court abused its discretion in awarding fees to the surviving spouse's attorney. The judgment of the Court of Appeals is affirmed in part and reversed in part.


Cases posted the week of 02/18/2002
State vs. Walter Lee Allen - E1998-00416-SC-R11-CD View
State vs. Walter Lee Allen - E1998-00416-SC-R11-CD ( Dissent) View
Jefferson County - The defendant, Walter Lee Allen, was indicted for aggravated robbery. He was convicted of the lesser-included offense of robbery and received a ten-year sentence. The Court of Criminal Appeals affirmed the conviction and sentence. We granted permission to appeal to review two issues: (1) whether a variance existed between the indictment alleging robbery "by violence" and the proof showing robbery by pointing a gun at the victim; and (2) whether the trial court erred by failing to instruct the jury on facilitation of robbery as a lesser-included offense. We conclude that no variance existed because pointing a deadly weapon at the victim constitutes robbery "by violence." We further conclude that the failure to instruct on facilitation of robbery was reversible error under the circumstances of this case. Accordingly, we reverse the judgment of the Court of Criminal Appeals and remand the case for a new trial.


Cases posted the week of 02/03/2002
State vs. Jerry W. Yancey, Jr. - M1999-02131-SC-R11-CD View
State vs. Jerry W. Yancey, Jr. - M1999-02131-SC-R11-CD ( Dissent) View
Williamson County - We granted this appeal to determine the following issues: (1) whether the Court of Criminal Appeals, in reviewing the denial of pretrial diversion, erred by considering evidence presented at trial and failing to limit its review to evidence considered by the district attorney general; and (2) whether the trial court applied the correct standard in reviewing the district attorney general's denial of pretrial diversion pursuant to a petition for writ of certiorari. After a thorough review of the record and relevant authority, we hold that in reviewing the denial of pretrial diversion, the Court of Criminal Appeals erred in failing to limit its review to the evidence that was considered by the district attorney general and any factual disputes resolved by the trial court. We also hold that in considering the petition for writ of certiorari, the trial court failed to apply the proper standard of review, which requires that it determine whether the district attorney general has considered and weighed all of the relevant factors and whether there is substantial evidence to support the district attorney general's decision. Accordingly, the judgment of the Court of Criminal Appeals is reversed, and this case is remanded to the trial court to apply the appropriate standard of review.


Cases posted the week of 01/28/2002
State vs. Johnnie Bell, Jr. - E1999-00819-SC-S09-CD View
State vs. Johnnie Bell, Jr. - E1999-00819-SC-S09-CD ( Dissent) View
Sullivan County - We granted this appeal to determine the following issues: (1) whether the district attorney general abused his discretion by failing to consider and weigh evidence favorable to the defendant before denying the defendant's request for pretrial diversion; and (2) whether the trial court erred in upholding the denial of pretrial diversion despite the district attorney general's failure to consider and weigh evidence favorable to the defendant. A majority of the Court of Criminal Appeals recognized that the district attorney general abused his discretion by failing to consider and weigh all of the relevant factors, including evidence favorable to the defendant, but nevertheless concluded that the trial court properly found that substantial evidence supported the denial of pretrial diversion. After a thorough review of the record and relevant authority, we hold that when the district attorney general denies pretrial diversion without considering and weighing all the relevant factors, including substantial evidence favorable to the defendant, there is an abuse of prosecutorial discretion. We further hold that in such a case, the proper remedy under the applicable standards of review requires a remand for the district attorney general to consider and weigh all of the relevant factors to the pretrial diversion determination. The judgment of the Court of Criminal Appeals is reversed, and this case is remanded for the district attorney general's further consideration of the defendant's pretrial diversion application in a manner consistent with this opinion.

Whirlpool Corp. vs. Ketkeo Nakhoneinh - M2000-01965-SC-WCM-CV View
Davidson County - We granted this appeal to determine whether the employee proved by a preponderance of the evidence that (1) she complied with the notice requirement of Tenn. Code Ann. § 50-6-201 and that (2) her injury was caused by her employment as required by Tenn. Code Ann. § 50-6-103(a). We hold that she complied with the notice requirement and that her injury arose out of her employment. The judgment of the trial court and the Special Workers' Compensation Appeals Panel is reversed. The case is remanded to the trial court for proceedings consistent with this opinion.


Cases posted the week of 01/21/2002
State v. John Farner, Jr. - E1999-00491-SC-R11-CD ( Rehear Petition) View


Cases posted the week of 01/07/2002
State v. Marcus Morrow - M1999-00769-SC-R11-CD View
Maury County - We granted this appeal to determine whether Tenn. Code Ann. § 41-2-128 authorizes a court other than a general sessions court to grant work release to a defendant convicted of driving under the influence of an intoxicant (DUI), second offense. We hold that Tenn. Code Ann. § 41-2-128 does not permit a circuit court to grant work release to DUI second offenders during the forty-five-day minimum mandatory sentence. The holding of the Court of Criminal Appeals is affirmed. The case is remanded to the trial court for proceedings consistent with this opinion.