This case arose after a TimberPro TL735B harvester owned by logging operator J.W. Smith was destroyed by an electrical fire, which Smith attributed to a manufacturing defect in the machine’s wiring protection. Following an earlier appeal that narrowed the claims, the trial court found that Woodland Equipment, Inc., the seller, had breached the implied warranty of merchantability by failing to install a rubber grommet or box connector on the wires. However, it ruled that Smith’s leaving the master switch on was the “last precipitating cause” of the fire, relieving Woodland of liability, while prospectively calculating damages at $330,000 based on the harvester’s pre-fire value minus salvage. On appeal, the Tennessee Court of Appeals reversed the causation ruling, holding that Smith’s conduct was a foreseeable use rather than an intervening cause and did not bar recovery under the warranty claim. It affirmed the trial court’s damage valuation and remanded for further proceedings.
This case arose when Arkansas residents Vicki and Charles Mobley sued the State of Arkansas, its highway department, and a state employee in Tennessee circuit court, alleging negligence in a vehicle accident on the Hernando Desoto Bridge; the plaintiffs claimed the Arkansas vehicle was improperly parked without warnings on the Tennessee side of the bridge. The defendants moved to dismiss on grounds including sovereign immunity and comity, supported by an interagency memorandum between the states and the fact that the plaintiffs had already filed related claims in Arkansas. The trial court granted dismissal based on comity, and the Tennessee Court of Appeals affirmed. The appellate court reasoned that Tennessee had minimal interest in adjudicating a dispute involving only Arkansas parties, that Arkansas sovereign immunity principles were compatible with Tennessee public policy, and that extending comity promoted harmonious interstate relations and reciprocal treatment for Tennessee defendants in other states.
This case arose from a long-running 2002 Tennessee proceeding to dissolve the nonprofit Pee Wee Wisdom Child Development Center, in which suspended attorney Homer Cody had previously represented parties before being disqualified and later disciplined. After multiple suspensions culminating in disbarment, Cody filed a pro se petition for contempt and sanctions in the original case, naming himself as petitioner and alleging that the receiver and other attorneys had improperly sought his disqualification and reported him to the Board of Professional Responsibility. The trial court denied the petition sua sponte, finding that Cody was never a party to the litigation, had not sought to intervene, and was attempting to circumvent his suspension from practicing law. The Court of Appeals affirmed, holding that a suspended attorney has no right to file pleadings under Tennessee Supreme Court Rule 9 and that Cody lacked standing because he was not a party and had no valid basis to invoke the court’s contempt power in this manner.
This case involved a declaratory judgment action brought by Brian T. Sparks, a co-trustee and beneficiary of the Willard R. Sparks Revocable Trust 2004, against the managing trustee and other co-trustees. Sparks sought a detailed accounting of the trust’s affairs and a plan for liquidating and distributing its approximately $200 million in non-liquid assets, claiming he had not received sufficiently detailed information despite receiving monthly and audited financial statements for years. The probate court dismissed the petition for lack of a justiciable controversy, finding no allegations of wrongdoing and noting that Sparks, as co-trustee, already had access to extensive financial reports. The court then granted the managing trustee’s motion for Rule 11 sanctions against Sparks, awarding $200,000 based on inaccuracies and deficiencies in the pleadings. The Court of Appeals affirmed, holding that the trial court did not abuse its discretion in dismissing the case or imposing sanctions.
Purchasers Kenneth and Debra Fulmer sued sellers Jeffrey and Debra Follis for fraud, fraudulent misrepresentation, fraudulent inducement, and fraudulent concealment after buying a house that had undisclosed severe water damage to the east garage wall. The trial court ruled for the purchasers on all claims. The Court of Appeals reversed, holding that the purchasers could not prove reasonable reliance—an essential element of each claim—because the home inspection report had placed them on notice of possible rainwater intrusion and the suspicious board covering the wall, yet they failed to exercise ordinary diligence by invoking their contractual right to further inspect or repair the issue before closing. The appellate court therefore remanded the case for dismissal.
This case concerns a third-party company's attempt to access court records from a 2014 minor's personal injury settlement that had been sealed by an agreed order citing the child's privacy interests. After the first appeal held that judicial records are presumptively open and required the trial court to articulate a compelling reason for continued sealing, the trial judge on remand again denied access, citing only "confidential information pertaining to the minor plaintiff" without further explanation. The Court of Appeals reversed, holding that neither the trial court nor the parties had identified any overriding interest sufficient to overcome the presumption of openness. It ordered that the records be made available to the petitioner and directed reassignment to a different trial judge.
