Thomas Gray Hull

The case concerns Angela Carswell's ERISA challenge to the termination of her long-term disability benefits by the Raytheon Employees Disability Trust, administered by MetLife, after an initial court-ordered reinstatement. The plan granted MetLife discretionary authority to determine eligibility, so the court applied an abuse-of-discretion standard of review to the updated administrative record. That record included medical examinations indicating Carswell could perform sedentary or semi-sedentary work, a transferable-skills analysis showing she had relevant electronics-assembly experience, and evidence of available jobs in her area. The court concluded that MetLife's decision to terminate benefits based on this evidence was rational under the plan's definition of total disability. It therefore granted judgment on the administrative record to the defendants and dismissed the action.

labor & employment

In Frontier Health Inc. v. Shalala, a psychiatric hospital sought a preliminary injunction to prevent the Secretary of Health and Human Services from terminating its participation in Medicare and Medicaid programs before completing the administrative appeal process. The court held that it lacked jurisdiction to review the merits of the termination decision prior to exhaustion of administrative remedies under 42 U.S.C. § 405(g), but found it had authority under 28 U.S.C. § 1331 to grant injunctive relief where termination would effectively deny later judicial review. Applying the four-factor test for preliminary injunctions, the court determined that the hospital showed a substantial likelihood of success on appeal, would suffer irreparable harm including potential closure and loss of revenue, and that the balance of harms and public interest favored maintaining the hospital's certification during the appeals process. The court therefore enjoined the Secretary from terminating participation or notifying others of any termination until the administrative process concluded.

healthcarefederal powerprocedurebusiness & regulatory

In Herman v. United States, taxpayers who purchased medical equipment from a bankrupt hospital for $40,000 and later donated it to a new nonprofit hospital sought refunds of income taxes and penalties after the IRS limited their charitable deductions under IRC Section 170 to the purchase price and imposed gross valuation misstatement penalties. The court granted the taxpayers' motion for summary judgment, finding them entitled to deductions based on the equipment's higher appraised fair market value (around $500,000 each) and refunds of the assessed amounts plus interest. The reasoning centered on the reliability of the appraisals obtained through the hospital administrator, which were not procured or influenced by the taxpayers, reflected arm's-length professional estimates rather than liquidation value, and supported reasonable cause to avoid penalties; the low bankruptcy purchase price was deemed a distress sale that did not establish fair market value for the donation.

taxes

This case concerns a challenge by African-American voters in Hamilton County, Tennessee, to the county's use of at-large, county-wide elections for circuit court, criminal court, chancery court, and general sessions judges. Plaintiffs alleged that the system violated Section 2 of the Voting Rights Act and the Fifteenth Amendment by diluting minority voting strength. Applying the Gingles preconditions and the totality of circumstances, including Senate factors, the court found that black voters were sufficiently numerous and geographically compact to form a majority in a single-member district, were politically cohesive, and that white bloc voting usually defeated their preferred candidates, resulting in vote dilution that outweighed the state's interest in maintaining at-large elections with jurisdiction-wide linkage. The court therefore held that the at-large system violated the Voting Rights Act and ordered the Tennessee legislature to submit a remedial plan, such as districting or cumulative voting, within ninety days.

electionscivil rights

This case involved Blue Diamond Coal Company, a former signatory to National Bituminous Coal Wage Agreements that stopped participating in United Mine Workers of America benefit funds after 1964, challenging the constitutionality of the Coal Industry Retiree Health Benefit Act of 1992's super-reachback provision that assigned retired miners and orphans to past operators for health benefit funding. The district court denied Blue Diamond's summary judgment motion and granted the motions of the Secretary of Health and Human Services and the Combined Fund trustees. The court reasoned that the Act was a rational legislative response to the financial crisis in the UMWA trusts resulting from industry decline and orphaned retirees, allocating proportional responsibility to former participants in a manner comparable to other upheld economic regulations on pensions and black lung benefits, and thus did not violate the Due Process or Takings Clauses of the Fifth Amendment.

business & regulatorylabor & employmenthealthcare

This case involved the IRS appealing a bankruptcy court ruling in favor of Chapter 13 debtors Joey and Letha Bentley regarding their tax liability for FICA and FUTA taxes on drivers they hired for their trucking business. The bankruptcy court granted summary judgment to the debtors, finding they qualified for the safe haven provisions of Section 530 of the Revenue Act of 1978 by treating drivers as independent contractors rather than employees, based on industry practice for 1990 and 1991. The district court affirmed, holding that the debtors' affidavits, including from a competitor, established a long-standing practice in a significant segment of the trucking industry, and the IRS's evidence did not create a material factual dispute. The court also upheld the denial of additional discovery time for the IRS.

taxesbusiness & regulatorylabor & employment

This case is a strict liability products liability action under the Tennessee Products Liability Act. The defendant asked the court to instruct the jury on comparative fault, arguing that the Tennessee Supreme Court's decision in McIntyre v. Ballentine required it even in pure strict liability cases. The court denied the request. It reasoned that McIntyre only replaced contributory negligence with comparative fault in general tort cases and did not address strict liability, which Tennessee precedent had long treated as theoretically incompatible with negligence defenses, and that extending the doctrine without clear state supreme court authority was inappropriate.

torts & liabilityprocedure

This case involved a challenge by Exchange Insurance Company to orders by the U.S. Department of the Interior forfeiting two reclamation bonds that had secured Tennessee surface mining permits. The bonds were originally issued under an interim state program but were later used, with the insurer's consent, to support permanent program permits under both state and federal law. After Tennessee repealed its mining regulations in 1984, the federal Office of Surface Mining assumed full regulatory authority and initiated forfeiture proceedings due to permit violations. The court reviewed the administrative record under 30 U.S.C. § 1276 and affirmed the forfeiture, holding that the bonds became enforceable under federal law and that the federal agency succeeded to the state's rights as obligee. The action was dismissed.

environmentbusiness & regulatoryfederal power

This case involved an Equal Pay Act claim brought by a female plaintiff against Sullivan County, alleging that she was paid less than her male predecessor in a comparable position. The court denied the defendants' motion for judgment as a matter of law or a new trial, finding that the jury verdict was supported by the evidence, the jury instructions were proper, and the claim was not barred by the statute of limitations because the defendants' ongoing failure to pay the plaintiff at the higher rate constituted a continuing violation under applicable EEOC regulations. The court granted the plaintiff's motion for damages, awarding compensatory damages calculated at the predecessor's higher pay level for the relevant period, an equal amount in liquidated damages based on the jury's finding of willfulness, attorney's fees, and costs, while denying prejudgment interest.

labor & employmentcivil rights

This case involved a claim for damages to computer equipment transported by Mayflower Transit in interstate commerce under a bill of lading and the Mayflower Green Light Guarantee transportation agreement. The court ruled that the Carmack Amendment preempts all state common law and statutory claims such as negligence, bailment, the Tennessee Consumer Protection Act, and bad-faith penalties, as well as the defense of comparative negligence, resulting in their dismissal. It decided that the only issues for the jury are whether the equipment was damaged during the defendant's interstate transport and, if so, the amount of full replacement or repair value under the agreement, while dismissing the claim for attorney's fees and deferring resolution of a counterclaim.

business & regulatoryfederal powertorts & liability

This case is a federal civil rights lawsuit under 42 U.S.C. § 1983 in which parents without bachelor's degrees challenged the constitutionality of a Tennessee statute (Tenn. Code Ann. § 49-6-3050(b)(7)) that requires such a degree to home-school children in grades 9-12 and the state education commissioner's policy of routinely denying statutory exemptions. The court granted the commissioner's motion to dismiss the action. It held that the claims were barred by res judicata because they were the same as those already litigated to a final judgment on the merits in an earlier state-court case (Crites v. Smith) involving the same home-schooling organization and some of the same plaintiffs (who were later voluntarily dismissed here). The court reasoned that the prior plaintiffs served as virtual representatives of the current plaintiffs due to their shared membership in the Home School Legal Defense Association and identical interests, making the parties in privity under Tennessee law.

civil rightsprocedurefamily law

This class action lawsuit was brought by approximately 2,600 riparian landowners and lessees along the Pigeon River and Douglas Lake in Tennessee against Champion International Corp., alleging that the company's pulp and paper mill discharges constituted a private nuisance and trespass by contaminating the water with toxic chemicals, discoloring it, and causing foul odors, thereby diminishing property values and causing personal discomfort; plaintiffs sought compensatory and punitive damages plus injunctive relief. After a mistrial, the parties submitted a proposed settlement for court approval under which Champion would pay $6.5 million into a charitable endowment fund for environmental and community benefits, with no direct payments to class members, no injunctive relief, and broad releases covering all past and future claims including personal injuries. Following a fairness hearing and review of objections from class members, the court declined to approve the settlement, reasoning that it failed to provide direct compensation to plaintiffs, improperly released future claims and personal injury actions, allowed ongoing pollution without restrictions, and directed funds to a perpetual endowment rather than distributing them to affected landowners. The court indicated it would approve a modified agreement featuring direct distributions to the class, narrower release language limited to known pre-settlement conduct, and caps on attorneys' fees.

environmentpropertytorts & liability

This case was a civil forfeiture action under the Federal Food, Drug, and Cosmetic Act in which the United States sought to seize and condemn certain disinfecting agents and sterilizing solutions as adulterated or misbranded devices. The government argued that the products were Class III devices sold without required pre-market approval and that their labeling inaccurately stated the percentage of sodium phenate. The court granted the United States' motion for partial summary judgment, finding the devices adulterated under 21 U.S.C. § 351(f)(1)(B) and misbranded under 21 U.S.C. § 352(a) based on uncontradicted declarations from FDA officials, and ordered the articles condemned.

business & regulatoryhealthcare

This case is a class action by owners, lessees, and business operators of property along the Pigeon River and Douglas Lake against Champion International Corporation, alleging that the company's pulp and paper mill contaminated the river with toxic substances including dioxins, interfering with their property rights via nuisance and trespass. The court granted the defendant's motion to dismiss claims for damages prior to January 1988, limiting recovery to the three years before the suit's filing under Tennessee's statute of limitations, on the reasoning that plaintiffs had long known of the river's pollution and any fraudulent concealment did not toll the limitations period or extend the damages timeframe. It denied motions to dismiss non-economic damages such as discomfort and anxiety, to dismiss permanent damages claims, and to bifurcate punitive damages from the liability phase, while deferring a final ruling on the trespass claim until the close of proof.

environmentpropertyproceduretorts & liability

The case involved Johnson City Medical Center Hospital seeking a refund of FICA taxes paid on wages earned by part-time employees who were simultaneously enrolled in a nursing degree program at East Tennessee State University. The hospital claimed these wages qualified for the student nurse exemption under Internal Revenue Code Section 3121(b)(13). The court ruled against the hospital and entered judgment for the United States, dismissing the refund claims. It applied Revenue Ruling 85-74, finding the exemption inapplicable because the employees received no academic credit for their work, the services were not incidental to their training, and their earnings were not nominal.

taxeslabor & employment

This case is a civil forfeiture action under the Federal Food, Drug, and Cosmetic Act in which the United States sought to seize and condemn certain disinfecting agents and sterilizing solutions as adulterated or misbranded devices. The court first denied the defendants' motion to dismiss, holding that the products qualify as devices under 21 U.S.C. § 321(h) because they are intended to mitigate or prevent disease when used on medical equipment and that jurisdiction exists under 21 U.S.C. § 334. In a later order, the court denied the claimant's motion to withdraw its claim, reasoning that allowing withdrawal after the government had invested substantial resources would be unfair to the public and required the claimant to respond to the government's motion for partial summary judgment.

business & regulatoryhealthcareprocedure

The case was an action by the United States to recover $158,300 in civil penalties assessed against Donovan Lueking under the Surface Mining Control and Reclamation Act of 1977 for violations during his coal mining operations in Tennessee, after Lueking failed to challenge or pay the penalties administratively. The court held that the federal five-year statute of limitations barred eight of the eleven claims because it began running on the dates of the original notices of violation and cessation orders rather than the later final penalty orders, and one additional claim was barred by res judicata from prior litigation. It rejected Lueking's arguments that the penalties had been discharged in his bankruptcy, finding them non-dischargeable penal obligations rather than compensation for pecuniary loss, and that laches applied to the remaining claims. The court entered judgment for the United States on the three non-barred penalties, plus interest and costs.

environmentbusiness & regulatory

This case involved a bankruptcy trustee's claims against a law firm and its partners for recovering an $8 million preference and over $5 million in fraudulent conveyances under Bankruptcy Code sections 547, 548, and 550, arising from transfers by Southern Industrial Banking Corp. to its principals and related redemptions of investment certificates. The district court denied the defendants' motion to vacate the bankruptcy court's judgment for lack of jurisdiction, ruling that Granfinanciera did not apply because the firm had filed a claim against the estate and waived any jury trial right by not demanding one. The court affirmed the bankruptcy court's determinations that the transfers were avoidable preferences and fraudulent conveyances, but limited the firm's liability to $359,101.60 plus the value of certain redemption notes. It also withdrew the reference for non-core claims such as malpractice and related torts, allowing the trustee to amend the complaint to pursue additional damages.

business & regulatoryprocedurefederal power

This case involved Ferrari suing Roberts for infringing its unregistered trademarks in the distinctive exterior shapes of its Daytona Spyder and Testarossa automobiles by producing and selling replica kits known as the Miami Spyder and Miami Coupe. Proceeding under § 43(a) of the Lanham Act and Tennessee common law, the court found for Ferrari on the federal unfair competition claim after a bench trial but dismissed the state claim. The court determined that the Ferrari designs qualified for protection as trade dress and that Roberts' replicas were virtually identical and likely to cause confusion among consumers. It entered a permanent injunction barring Roberts from manufacturing, selling, or distributing the Miami vehicles or using any Ferrari marks.

business & regulatory

The case involved disputes over the appropriate educational placement and funding for Kristi McClain, a severely retarded 19-year-old, under the Education for All Handicapped Children Act, specifically whether her placement at a private group home was suitable, if a residential component was educationally necessary, and which entity (Knox County) bore financial responsibility. The court affirmed the administrative law judge's determinations that Knox County was responsible for her education, that a residential placement was educationally necessary, and that the group home was not an appropriate educational placement, requiring the county to identify a suitable residential educational program. However, the court disagreed that the mother had knowingly waived her daughter's EAHCA rights by agreeing to the placement. It ordered Knox County to cover expenses at the group home from the transfer date until May 1, 1990, while finding an appropriate placement.

civil rightsfederal power