Andrew Bettis Aviation, LLC v. Howard Wayne Lanier

This appeal presents two issues: (1) whether Appellant preserved his evidentiary issues
concerning the trial court’s admission of video evidence in a jury trial, and (2) whether,
following a bench trial, the trial court made sufficient findings under Rule 52.01 when
rejecting Appellant’s COBRA claim. Because Appellant failed to include the evidentiary
issues in a motion for new trial as required by Tennessee Rule of Appellate Procedure 3(e),
and because Tennessee Rules of Appellate Procedure 13(b) and 36(b) are not applicable,
we conclude that Appellant waived the evidentiary issues. Further, because the trial court’s
order does not make sufficient findings, we cannot conduct a meaningful review of the
COBRA issue, and we remand for compliance with Rule 52.01.