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Supreme Court Opinions - 3 rd Quarter 2008

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This Page Last Updated: May 01, 2008 at 10:02.31 hours

The following Opinions are available for viewing or download in PDF format:


Cases posted the week of 9/22/2008
Dennis Pylant v. State of Tennessee - M2005-02721-SC-R11-PC View
Cheatham County - We accepted this appeal to determine whether the post-conviction court erred in denying Petitioner Dennis Pylant’s claim of ineffective assistance of counsel at trial. In 2001, a jury convicted Petitioner of the first degree felony murder of two-year-old S.J.D. in the perpetration of aggravated child abuse. The Court of Criminal Appeals affirmed Petitioner’s conviction and this Court denied Petitioner’s application for permission to appeal. Petitioner filed a petition for post-conviction relief alleging ineffective assistance of counsel at trial. At the hearing, Petitioner adduced testimony about self-incriminating statements made by the victim’s mother but which trial counsel did not present to the jury at trial. The post-conviction court struck this testimony as hearsay and denied Petitioner’s claim for relief. The Court of Criminal Appeals affirmed the post-conviction court. We hold that the post-conviction court erred in striking the proffered testimony as hearsay. We also hold that, because the post-conviction court made no credibility findings with respect to the proffered witnesses, we are unable to reach the merits of Petitioner’s claim. Accordingly, we reverse the Court of Criminal Appeals’ judgment in this case and remand for a new post-conviction hearing.

State of Tennessee vs. Tyson Lee Day - M2006-00989-SC-R11-CD View
Separate Dissenting Opinion - View
Sumner County - After unsuccessfully moving to suppress evidence resulting from the traffic stop that led to his arrest, the defendant, Tyson Lee Day, pleaded guilty to third offense driving under the influence and driving on a revoked license. The plea agreement provided for reservation of a certified question of law regarding whether the traffic stop was based on reasonable suspicion, supported by specific and articulable facts, that a criminal offense had been or was about to be committed. On appeal, the Court of Criminal Appeals concluded that at the time the officer initiated the traffic stop, he lacked reasonable suspicion. Accordingly, the court reversed the judgment of the trial court and, because the question was dispositive, dismissed the case. We granted the State’s application for permission to appeal to consider the question of whether the community caretaking rationale for traffic stops justified the stop in this case. After carefully examining the certified question, however, we conclude that the community caretaking issue was not included within the scope of the question reserved for review. Accordingly, our review extends solely to the issue preserved, i.e., whether the traffic stop was based on reasonable suspicion, supported by specific and articulable facts, that a criminal offense had been or was about to be committed. We conclude that the facts do not support a finding of reasonable suspicion. Accordingly, we affirm the judgment of the Court of Criminal Appeals.

Cases posted the week of 9/15/2008
Michael Dwayne Edwards v. State of Tennessee, Wayne Brandon, Warden -
M2006-01043-SC-R11-HC View
Separate, Dissenting Opinion - View
Hickman County - We granted the State’s application for permission to appeal to consider whether the Court of Criminal Appeals erred in remanding this habeas corpus case to the trial court for a hearing on Michael Dwayne Edward’s claim that his sentence is illegal. After careful consideration we conclude that, even assuming the trial court erroneously classified Edwards as a persistent offender for sentencing, this non-jurisdictional error renders the judgment voidable, not void, and does not entitle Edwards to habeas corpus relief. Accordingly, we reverse the judgment of the Court of Criminal Appeals and reinstate the judgment of the trial court dismissing the habeas corpus petition.

Cases posted the week of 9/8/2008
Diane Downs, individually and as natural parent of Ryan Cody Downs v. Mark Bush, et al - M2005-01498-SC-R11-CV View
Separate Concurring and Dissenting Opinion - View
Davidson County - We granted the plaintiff’s application for permission to appeal in this wrongful death case to determine whether the trial court properly granted summary judgment to each of the defendants. The Court of Appeals affirmed the grant of summary judgment. Although the parties have raised several issues in this appeal, the central issue is the nature of the legal duty, if any, owed by the defendants to the plaintiff’s decedent. The decedent was socializing and consuming alcohol with the defendants. While riding in a four-door pick-up truck with the defendants, he became ill. The defendants stopped the truck on the side of an interstate highway so the decedent could vomit. After resuming the trip, the decedent rode in the bed of the truck and, for reasons unknown, exited it. After exiting the truck, he was struck by two vehicles and subsequently died. Upon careful review of the record and applicable authority, we conclude that there are genuine issues of material fact as to whether the defendants placed the decedent in the bed of the truck. Similarly, we conclude that there are genuine issues of material fact as to whether the decedent was helpless and whether the defendants took charge of him. Lastly, we hold that none of the defendants stood in any special relationship with the plaintiff’s decedent and consequently they did not assume any affirmative duty to aid or protect him. We therefore reverse the judgment of the Court of Appeals and remand this case to the trial court for further proceedings.

Colonial Pipeline Company v. John G. Morgan, TN Comptroller and TN State Board of Equalization, Members of the TN State Board of Equalization, Individually, as follows: Governor Phil Bredesen, Riley Darnell, Secretary of State, Dale Sims, State Treasurer -
M2006-00591-SC-R11-CV View
Davidson County - Colonial Pipeline Company filed suit for declaratory judgment, challenging the constitutionality of specified portions of the state tax code and seeking an injunction as to the enforcement of those provisions. The Chancery Court dismissed the action, holding that the company had failed to exhaust its administrative remedies. The Court of Appeals reversed and remanded. We granted an application for permission to appeal and, after consideration of the issues, hold that (1) a party making a constitutional challenge to the facial validity of a statute need not exhaust its administrative remedies, and that (2) the doctrine of sovereign immunity does not bar a suit for declaratory judgment asking state officers to be enjoined from enforcing such a statute so long as the action does not seek money damages. We, therefore, affirm the judgment of the Court of Appeals.

Doug Satterfield, as personal representative of the Estate of Amanda Nicole Satterfield, Deceased, vs. Breeding Insulation Company, Inc. and Alcoa, Inc., f/k.a Aluninum Company of America - E2006-00903-SC-R11-CV View
Separate Dissenting Opinion - View
Blount County - This appeal involves the efforts of the estate of a twenty-five-year-old woman who contracted mesothelioma to recover damages for her death. While she was alive, the woman filed a negligence action against her father’s employer, alleging that the employer had negligently permitted her father to wear his asbestos-contaminated work clothes home from work, thereby regularly and repeatedly exposing her to asbestos fibers over an extended period of time. After the woman died, the Circuit Court for Blount County permitted her father to be substituted as the personal representative of her estate. The employer moved for a judgment on the pleadings on the narrow ground that it owed no duty to its employee’s daughter. The trial court granted the motion. The deceased woman’s father appealed the dismissal of his daughter’s wrongful death claim. The Tennessee Court of Appeals reversed the trial court. Satterfield v. Breeding Insulation Co., No. E2006-00903-COA-R3-CV, 2007 WL 1159416 (Tenn. Ct. App. Apr. 19, 2007). We granted the employer’s application for permission to appeal to determine whether the deceased woman’s complaint can withstand a motion for judgment on the pleadings. We have determined that it does because, under the facts alleged in the complaint, the employer owed a duty to those who regularly and for extended periods of time came into close contact with the asbestos-contaminated work clothes of its employees to prevent them from being exposed to a foreseeable and unreasonable risk of harm.

Cases posted the week of 9/1/2008
State of Tennessee vs. Randy Lee Meeks and Ernest Lonnie Snyder, Jr. -
M2006-01385-SC-R11-CO View
Coffee County - This appeal involves the warrantless search of a motel room containing an actively operating methamphetamine laboratory. After the occupants of the room were indicted for manufacturing methamphetamine and for possessing methamphetamine and drug paraphernalia, they filed a motion in the Circuit Court for Coffee County seeking to suppress the evidence found in the motel room. The trial court granted the motion to suppress and dismissed the indictment. The State appealed, and the Court of Criminal Appeals reversed the trial court’s decision to suppress the evidence and vacated the order dismissing the indictment. State v. Meeks, No. M2006-01385-CCA-R3-CO, 2007 WL 1987797 (Tenn. Crim. App. July 10, 2007). We granted the defendants’ Tenn. R. App. P. 11 application for permission to appeal to address more fully the principles applicable to warrantless searches of actively operating methamphetamine laboratories when the State asserts that the officers were acting to avert a serious and immediate risk of injury to themselves or others. Like the Court of Criminal Appeals, we have determined that the trial court erred by granting the motion to suppress and by dismissing the indictment.

Cases posted the week of 8/25/2008
State of Tennessee vs. Marco M. Northern - M2005-02336-SC-R11-CD View
Separate Dissenting Opinion - View
Davidson County - We granted this appeal to consider whether the courts below correctly held that Missouri v. Seibert, 542 U.S. 600 (2004), does not bar the introduction into evidence of the defendant’s Mirandized videotaped confession which occurred after the defendant made an incriminating admission during a prior unwarned custodial interrogation. This Court has not previously interpreted and applied Seibert. After carefully considering the plurality opinion, the concurring opinions, and the dissenting opinions in Seibert, we conclude that the courts below correctly held that Seibert does not bar admission of the defendant’s videotaped confession. We further hold that this Court’s decision in State v. Smith, 834 S.W.2d 915 (Tenn. 1992), interpreting the right against self-incrimination provided by article I, section 9 of the Tennessee Constitution, does not bar admission of the defendant’s videotaped confession. Accordingly, we affirm the judgment of the Court of Criminal Appeals, which affirmed the defendant’s conviction of second degree murder but remanded for resentencing.

Cases posted the week of 8/11/2008
State of Tennesee v. Ariel Ben Sherman and Jacqueline P. Crank -
E2006-01226-SC-R11-CD View
Loudon County - A Loudon County grand jury indicted the defendant, Ariel Ben Sherman, and co-defendant, Jacqueline Crank, for child neglect. The trial court dismissed the indictment against Sherman. The Court of Criminal Appeals reversed and remanded. We granted Sherman’s application for permission to appeal to consider the issues presented for review, and hold as follows: (1) When deciding a motion to dismiss an indictment, a trial court may consider undisputed facts that are clearly and unequivocally agreed upon by the parties; (2) a person standing in loco parentis to a child may have a legal duty of care, the breach of which may result in criminal culpability; and (3) the State is not bound at the outset of a trial by the legal theories espoused in its bill of particulars. Because the trial court erroneously dismissed the indictment, we affirm the Court of Criminal Appeals, reinstate the indictment against Sherman, and remand the case for further proceedings consistent with this opinion.

State of Tennessee vs. Robert T. Downey - M2005-02335-SC-R11-CD View
Montgomery County - The defendant in this case was convicted of conspiracy to commit especially aggravated robbery, especially aggravated robbery, aggravated burglary, and reckless endangerment. The Court of Criminal Appeals affirmed his convictions but remanded for re-sentencing. We granted the defendant’s application for permission to appeal to consider the following issues: 1) whether the trial court erred in denying defendant’s motion to suppress his written statement; 2) whether the trial court erred by overruling defendant’s motion to dismiss the indictment when the State violated rules of discovery; 3) whether the State failed to prove the use of a deadly weapon; 4) whether there was sufficient evidence of conspiracy to use a deadly weapon; and 5) whether the verdict was contrary to the weight of the evidence. Neither party appealed the Court of Criminal Appeals’ decision to remand for re-sentencing. After considering these issues, we conclude that the trial court properly denied the defendant’s motion to suppress and motion to dismiss. We also hold that there was sufficient evidence to support all of the convictions. We therefore affirm the defendant’s convictions, while remanding to the trial court for re-sentencing under the Court of Criminal Appeals’ order.

Willis B. Amos, et al. v. The Metropolitan Government of Nashville and Davidson County - M2005-00932-SC-R11-CV View
Davidson County - Willis Bruce Amos and fifteen other individuals, each of whom was formerly employed in the police or fire departments of the Metropolitan Government of Nashville and Davidson County, filed suit, asking to have the lump-sum payments for unused vacation days paid at their retirement included in the formula determining the amount of their pension. Pursuant to applicable provisions of the Metro Code, the trial court granted a motion for summary judgment, holding that the lump-sum payments to Amos and the other individuals were not included in their “average earnings” for purposes of the calculations. The Court of Appeals upheld the judgment of the trial court. We affirm.

Marc Eskin and Karen Eskin, each individually & as parents & next friends to Brendan Eskin and Logan Eskin v. Alice B. Bartee, et al - W2006-01336-SC-R11-CV View
Shelby County - This appeal involves claims for negligent infliction of emotional distress made by two family members of a child who was seriously injured in an automobile accident. In their complaint filed in the Circuit Court for Shelby County, the injured child’s mother and brother alleged that they had sustained severe emotional injuries after they observed him lying on the pavement in a pool of blood. The injured child’s parents served a copy of the complaint on their automobile insurance company because the driver of the automobile that struck their son lacked adequate insurance. The insurance company moved for a partial summary judgment on the negligent infliction of emotional distress claim because neither the injured child’s mother nor his brother had seen or heard the injury-producing accident. The trial court granted the insurance company’s motion, and the injured child’s mother and brother appealed to the Tennessee Court of Appeals. The appellate court reversed the summary judgment and remanded the case for further proceedings. We granted the insurance company’s Tenn. R. App. P. 11 application for permission to appeal to determine whether the Court of Appeals correctly permitted these negligent infliction of emotional distress claims to proceed. We have determined that persons who observe an injured family member shortly after an injury-producing accident may pursue a claim for negligent infliction of emotional distress.

Tammy Renee Maggart v. Almany Realtors - M2005-02532-SC-R11-CV View
Sumner County - In this personal injury case, the plaintiff was an employee of the defendant and was injured on the job. The trial court granted the defendant’s motion for summary judgment concluding that the plaintiff had executed a general release of liability in favor of the defendant. The Court of Appeals reversed, holding that the release was invalid as against public policy. Upon thorough consideration of the record and of the applicable law, we hold that summary judgment was inappropriate because the release of liability only covered accidents occurring while the plaintiff was running errands off-premises and did not cover the particular accident at issue in this case. Therefore, we affirm the Court of Appeals’ decision denying summary judgment, on alternate grounds, and remand this case to the trial court for further proceedings.

Billy Anderson v. Westfield Group - M2006-01571-SC-WCM-WC View
This workers’ compensation appeal involves an employer’s liability for medical benefits stemming from injuries that occurred subsequent to an original compensable injury. Following a 2001work-related injury to his elbow, the employee and his employer settled the employee’s claim for workers’ compensation benefits. The settlement obligated the employer to pay future medical bills resulting from the elbow injury. Shortly after undergoing corrective surgery on the injured elbow in 2004, the employee burned his hand while cooking at home. While recuperating from the burn to his hand, he suffered additional injuries to his hand in a fall near his sister’s home. The employee filed a petition seeking to recover medical expenses for these two injuries to his hand on the basis that the medical expenses associated with these injuries were the direct and natural consequence of the original work-related injury to his elbow. The trial court found that the medical expenses sought by the employee were the result of intervening causes, namely the employee’s own negligence, and denied the petition. The Special Workers’ Compensation Appeals Panel reversed, finding that the subsequent injuries were the direct and natural consequence of the original compensable injury and that there were no intervening causes. Upon review of the record and applicable law, we hold that the injuries to the employee’s hand were due to his own negligence, and therefore, the employer is not required to pay the medical bills associated with those injuries. Accordingly, we reverse the Panel’s decision and affirm the judgment of the trial court.

Cases posted the week of 7/7/2008
Jeremy Flax and Rachel Sparkman, as the Natural Parents of Joshua Flax, deceased; Rachel Sparkman, Individually v. DaimlyerChrysler Corporation; and Louis A. Stockell, Jr. - M2005-01768-SC-R11-CV View
Separate Concurring and Dissenting Opinion (Justice Clark) - View
Separate Concurring and Dissenting Opinion (Justice Koch) - View
Separate Concurring Opinion (Justice Wade) - View
Davidson County - The plaintiffs filed this products liability case against DaimlerChrysler seeking damages for the wrongful death of their son and for emotional distress suffered by the mother. The plaintiffs also sought punitive damages. We granted review to determine: 1) whether a negligent infliction of emotional distress claim brought simultaneously with a wrongful death claim is a “stand-alone” claim that requires expert medical or scientific proof of a severe emotional injury; 2) whether the evidence presented at trial was sufficient to support an award of punitive damages; 3) whether the punitive damages awarded by the trial court were excessive; and 4) whether the trial court erred by recognizing the plaintiffs’ second failure to warn claim. We hold that the simultaneous filing of a wrongful death suit does not prevent a negligent infliction of emotional distress claim from being a “stand-alone” claim. Therefore, negligent infliction of emotional distress claims brought under these circumstances must be supported by expert medical or scientific proof of a severe emotional injury. In addition, we conclude that the punitive damages awarded by the trial court were adequately supported by the evidence and were not excessive. Finally, we hold that the trial court erred by recognizing the plaintiffs’ second failure to warn claim but conclude that the error did not prejudice the judicial process or more probably than not affect the jury’s verdict. Accordingly, we affirm the Court of Appeals’ reversal of the compensatory and punitive damage awards based on the negligent infliction of emotional distress claim and reverse the Court of Appeals’ decision to overturn the punitive damage award related to the plaintiffs’ wrongful death claim.

Dennis J. Hughes v. Board of Professional Responsibility of the Supreme Court of Tennessee - M2007-01562-SC-R3-BP View
Separate Concurring/Dissenting Opinion - View
Davidson County - This is a direct appeal from a judgment of the trial court, which set aside a decision by a hearing panel designated by the Board of Professional Responsibility granting a disbarred attorney’s petition for reinstatement of his law license. The issue presented is whether the attorney, who was convicted of bribing a witness and conspiracy to bribe a witness in a criminal trial, has met the criteria for immediate reinstatement to the practice of law. Although the panel properly determined that the evidence clearly and convincingly proved the moral qualifications of the attorney and his knowledge of state law, we hold that the evidence failed to so meet the threshold as to the third requirement–that reinstatement would not be detrimental to the standing of the bar, the administration of justice, and the interest of the public. The judgment of the trial court is, therefore, affirmed.