Timmy Sykes et al. v. Chattanooga Housing Authority et al.

The plaintiffs, former employees of the Chattanooga Housing Authority (“CHA”), brought retaliatory discharge actions against the CHA and the Chief of the CHA Public Safety Department, pursuant to the Tennessee Public Protection Act, Tennessee Code Annotated section 50-1-304 (2008 & Supp. 2010), and the Tennessee Human Rights Act (“THRA”), Tennessee Code Annotated section 4-21-301 (2005). The trial court granted the defendants summary judgment on all claims. On appeal, the Court of Appeals vacated summary judgment on the THRA claim, finding genuine issues of material fact, and affirmed the trial court’s judgment in all other respects. We affirm the grant of summary judgment on the Tennessee Public Protection Act claims because the undisputed facts establish that the plaintiffs cannot prove the essential element of an exclusive causal relationship between the plaintiffs’ whistleblowing activity and their discharge, as required by the statute. We also affirm the Court of Appeals’ ruling vacating summary judgment in defendants’ favor on the THRA claims because there are genuine issues of disputed fact making summary judgment improper.