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

The case involved a worker's compensation claim by an employee who slipped and injured his back while cleaning oil at the defendant's plant shortly after being hired in 1971. The employer defended by alleging that the employee had falsified his application regarding prior back injuries, arguing this misrepresentation barred benefits under company policy and principles against profiting from fraud. The court noted the absence of an explicit statutory provision on the issue but adopted a three-factor test from Larson's treatise requiring a knowing willful false representation about physical condition, substantial reliance by the employer in hiring, and a causal connection to the injury; finding the record unclear on willfulness given the employee's illiteracy and on causation, it remanded for additional evidence rather than awarding or denying benefits outright.

labor & employment

The case involved a conviction for passing a worthless check in the amount of $65. The trial court found the defendant guilty based on eyewitness identification and other evidence, but the Court of Criminal Appeals reversed, finding the evidence preponderated against the verdict. The Tennessee Supreme Court reversed the appellate decision and reinstated the conviction, reasoning that the defendant failed to carry the burden of showing the evidence preponderated against the jury's verdict, which is presumed correct after approval by the trial judge, and that conflicts in testimony regarding identification and any alleged settlement discussions were resolved in favor of the state.

criminal lawprocedure

The case involved respondent Manning's convictions on two counts of selling legend drugs and one count of possessing them, resulting in consecutive prison sentences. The Court of Criminal Appeals dismissed the possession conviction due to an allegedly unlawful search and reversed the sales convictions based on prejudicial cross-examination. The Tennessee Supreme Court reversed those rulings and reinstated all convictions. It held that the officers had founded suspicion to stop the vehicle amid recent burglaries, that Manning voluntarily consented to the search, and that any errors in cross-examination were either proper for credibility or harmless. The Court further noted that Manning's own testimony disclaimed knowledge of the drugs, waiving any search issue.

criminal lawprocedure

In Veach v. State, the defendant was convicted of driving a vehicle on a public highway while his license was revoked, with the revocation stemming from his involvement in an accident under T.C.A. Section 59-1204 of the Tennessee Financial Responsibility Act, which allowed revocation without a prior hearing to assess potential liability. The Tennessee Supreme Court reversed and dismissed the conviction. The court reasoned that the U.S. Supreme Court's decision in Bell v. Burson, issued before Veach's trial, established that revoking a driver's license without a hearing on the reasonable possibility of liability violates due process under the Fourteenth Amendment, rendering the revocation unconstitutional and the subsequent conviction invalid.

criminal lawcivil rights

This case arose after a pedestrian recovered damages from the City of Knoxville for injuries caused by tripping on a protruding metal trapdoor in a public sidewalk that provided access to a leased building. The City, after satisfying the judgment, sued the building's lessee (and its dissolved corporation's trustees and liability insurer) for indemnity, having previously received a credit under the Uniform Contribution Among Tort-Feasors Act for a settlement paid by the lessee. The Chancellor awarded indemnity, and the Tennessee Supreme Court affirmed. The court held that the trapdoor had been installed exclusively for the abutting landowner's benefit, making the landowner primarily responsible; it rejected arguments that the City's acceptance of a statutory credit barred indemnity or that corporate dissolution prevented suit, and it applied the rule allowing a municipality to recover from a property owner who creates an artificial sidewalk hazard for private use.

torts & liabilityprocedure

In Holt v. State Farm Mutual Automobile Insurance Co., State Farm sought a declaratory judgment that it owed no liability coverage or duty to defend under two auto policies for personal injury claims by Jimmy Holt arising from a car accident in which his brother Richard was driving a vehicle insured under policies naming their mother as the primary insured. The court affirmed the chancellor's ruling that coverage was excluded, finding that the policies' relative resident exclusion clauses barred Jimmy's claim because he lived with his mother, that the Financial Responsibility Act did not apply or override the exclusions, and that uninsured motorist coverage was unavailable because the vehicle was insured rather than uninsured. The core reasoning was that the policy language expressly excluded family members residing in the same household, the parties were free to contract for such exclusions since the Act's requirements were not triggered, and the statute's purpose did not extend to mandating coverage for specifically excluded claimants.

torts & liabilitybusiness & regulatory

The case involved an employee seeking worker's compensation benefits after being injured when a bottle struck him in the face while he was operating a forklift at his workplace. The employee had been "goosing" a coworker, which prompted the coworker to react and drop the bottle, despite a prior warning not to do so. The trial court awarded medical expenses, finding the injury arose out of employment and did not constitute willful misconduct. On appeal, the court reversed, holding that the injury resulted from the employee's willful misconduct—intentional act in violation of orders with an element of perversity—and did not arise out of his employment duties.

labor & employment

The case involved a dispute over Tennessee gross receipts privilege taxes paid by a chain of vending machine corporations. The companies paid their first quarterly installment four days late in August 1970 and later sought to continue quarterly payments while claiming credits for franchise and excise taxes paid. The Commissioner of Revenue enforced a regulation requiring full annual payment plus penalties for missing the initial deadline, which the companies paid under protest before suing for a refund. The trial court ruled that the taxpayers had not forfeited the quarterly option under T.C.A. § 67-4318, but the Supreme Court reversed, holding that the statute's plain language requires payment of the entire annual tax if the August 1 installment is missed, as the tax is annual in nature and the quarterly option is lost upon default.

taxesbusiness & regulatory

This case was a workers' compensation proceeding in which petitioner Anna Ruth Sizemore sought additional benefits after injuring her back in a fall at work on October 4, 1968. The employer's insurance carrier made voluntary payments of temporary total benefits and medical expenses, with the final payment to Dr. Whittle mailed on February 12, 1969, and received and cashed on February 14, 1969. Suit was filed exactly one year later on February 14, 1970. The trial court sustained the statute of limitations defense under T.C.A. Section 50-1003, ruling that payments ceased upon mailing. The Tennessee Supreme Court reversed and remanded, holding that voluntary payments cease only upon receipt by the creditor and that the action was therefore timely.

labor & employmentprocedure

In Hendrix v. Ray-Ser Dyeing Company, plaintiff James R. Hendrix sought workers' compensation benefits after injuring his foot in a fall while painting a smoke stack at the defendant's dyeing facility as an employee of John Scott, whom the defendant had hired for the job. The trial court denied benefits on grounds that Scott was an independent contractor and the plaintiff was a casual employee. The Supreme Court affirmed the judgment, holding that the defendant was not a principal contractor liable under T.C.A. Section 50-915 because it had not contracted out work related to its core dyeing business but instead maintained its own premises, and the plaintiff was not engaged in the usual course of the defendant's operations.

labor & employment

The case involved natural gas pipeline companies operating interstate lines through Tennessee challenging the state's imposition of use taxes on natural gas consumed in compressor stations to maintain pressure in the pipelines. The companies had paid the taxes under protest after the state removed a prior exemption for natural gas. The court ruled that the tax was not applicable, as the gas did not come to rest in the state but remained part of interstate commerce, and affirmed the lower court's decision to refund the payments. The reasoning centered on the continuous flow of the gas and its role as an integral part of the interstate transportation, supported by precedent from Helson v. Kentucky interpreting the Commerce Clause.

taxesbusiness & regulatoryfederal power

In Monk v. Ramsey, a minor plaintiff recovered a judgment against her husband for personal injuries from a pre-marriage car accident in which she was a passenger, and her father obtained a judgment for medical expenses and loss of services; the suits were filed after the parties married. The defendant appealed, arguing that the marriage extinguished both claims under common law. The Tennessee Supreme Court held that the wife's antenuptial tort claim was extinguished by the subsequent marriage, as the common law rule of marital unity had not been abrogated by statute or the Financial Responsibility Law, reversing the judgment in her favor. However, the court affirmed the father's judgment, reasoning that his cause of action for medical expenses and loss of services was separate and distinct from the daughter's, even though derivative in nature, and had accrued prior to the marriage.

family lawtorts & liability

This case arose from an accident in which a young child was struck by a passing car while crossing a residential road to reach an ice cream truck parked in the roadway by defendants Hastings and Heffelfinger. The plaintiffs sued the ice cream vendors on common-law negligence grounds, alleging they owed a duty to the children they attracted and failed to maintain a lookout or warn of traffic, and also on a statutory count for improper parking. The trial court directed a verdict for the defendants, but the Court of Appeals reversed on both counts; on review, the Tennessee Supreme Court affirmed the reversal only as to the common-law count and remanded for trial, while upholding the directed verdict on the statutory count. The court reasoned that the vendors owed a duty of care because they invited children to a dangerous location, that the foreseeability of harm from passing motorists made proximate cause a jury question, and that the parking statute did not apply in a residential district. The court further held that any negligence by the driver would not necessarily supersede the defendants' liability.

torts & liability

This case arose from a 1965 automobile accident in which a teenager driving a pickup truck lost control after hitting a wooden culvert that had been depressed by a heavy tractor-trailer carrying a bulldozer. The plaintiffs sued the trucking company and its driver for negligence in hauling the load without inspecting the road or warning of damage to the culvert. A jury found for the plaintiffs, and the Court of Appeals affirmed liability after some remittiturs, but the Tennessee Supreme Court reversed and dismissed the suits. The Court held that the driver's uncontradicted testimony established he neither saw nor felt the culvert's collapse and had crossed a similar load the day before without incident, so he could not have reasonably foreseen or anticipated the danger to other motorists. Without proof of proximate negligence, the defendants were entitled to a directed verdict.

torts & liabilityprocedure