Chester C. Chattin

This case involved former residents of Clover Bottom Hospital and School, a state institution, who sued in Tennessee chancery court to recover unpaid minimum wages under the federal Fair Labor Standards Act for maintenance work performed while living there. The state defendants moved to dismiss on grounds of sovereign immunity under the Tennessee Constitution and statutes, arguing that state courts lacked jurisdiction over such claims against the state. The chancellor denied the motion, and the Tennessee Supreme Court affirmed, holding that the 1966 FLSA amendments validly extended coverage to state hospital and school employees and that Congress's commerce power prevented the state from asserting immunity to bar suits in its own courts. The court adopted the reasoning of Justice Marshall's concurrence in Employees v. Missouri Public Health Dept. that the FLSA expressly authorized actions in any court of competent jurisdiction. The case was remanded for further proceedings on the wage claims.

labor & employmentfederal power

This case involved a challenge to the constitutionality of Tennessee's 1974 Open Meetings Act (Chapter 442), which declared that public policy formation is public business and required governmental bodies to give "adequate public notice" of meetings. The City of Memphis and other complainants filed a declaratory judgment action in chancery court arguing the notice provision was unconstitutionally vague and ambiguous, and the chancellor agreed, striking down that portion of the Act. The Tennessee Supreme Court reversed on appeal, ruling that the phrase means notice based on the totality of the circumstances sufficient to fairly inform the public, that it was not unconstitutionally vague in this remedial (non-penal) context, and that doubts should be resolved in favor of constitutionality. The court remanded the case for entry of a decree consistent with its opinion.

free speechprocedure

This case involved a police officer seeking workers' compensation benefits after suffering a myocardial infarction while on duty, alleging 100% permanent disability. The trial court awarded benefits under the Workmen's Compensation Act, and the Tennessee Supreme Court affirmed. The court applied the statutory presumption in T.C.A. Section 6-639 that heart disease causing disability in full-time law enforcement officers is due to accidental injury in the course of employment, once prerequisites such as a pre-employment physical showing no heart disease are met. The prerequisites were satisfied here, and the sole medical testimony did not rebut the presumption, thereby establishing the required causal connection to employment.

labor & employment

This case involved a personal injury lawsuit by Charles Moulton and his wife against Ford Motor Company and a dealer after Moulton's 1969 Ford LTD veered off the road due to an alleged steering defect, causing serious injuries. The plaintiffs claimed negligence, breach of warranties, tortious misrepresentation, and strict liability in tort. The Supreme Court of Tennessee held that the tort-based claims were barred by the one-year statute of limitations, which began running when the car was delivered rather than at the time of the accident, and upheld the dismissal of the warranty claims because the manufacturers' disclaimers were valid under the Uniform Commercial Code. The court reasoned that the cause of action accrued upon delivery of the product, giving the defendants a vested right to repose after the limitations period, even though the injury occurred later.

torts & liabilityprocedure

The case involved a challenge by Southern Railway Company and South Central Bell Telephone Company to the validity of an amendment to Article 2, Section 28 of the Tennessee Constitution adopted by a limited constitutional convention in 1971 and ratified in 1973. The plaintiffs argued that the convention exceeded the scope of its call by sub-classifying tangible personal property, authorizing sub-classification of intangible personal property, and including certain tax exemptions not permitted by the call. The court held that the amendment was validly adopted, as the convention's actions were within the limitations of the call, which authorized classification of personal property and permitted the exemptions either as pre-existing or specifically allowed.

taxesproperty

In State v. McLennan, the defendant was convicted under Tennessee law of possessing burglarious instruments after police stopped his car at 3:30 a.m. as it left a closed service station in a business district with recent burglaries; officers observed tools like crowbars and a sledgehammer in plain view inside the vehicle when the driver exited to provide his license. The Court of Criminal Appeals reversed the conviction, holding that the stop amounted to an illegal arrest without probable cause. The Tennessee Supreme Court reversed that decision and reinstated the conviction, ruling that the officers had reasonable grounds for a brief investigatory stop based on the totality of circumstances—including the car's unusual appearance, prior sighting, and timing in a high-crime area—and that the visible evidence did not result from an unconstitutional search. The court clarified that such a stop for identification purposes is distinct from a formal arrest and does not require probable cause.

criminal lawprocedure