Supreme Court Requires Trial Courts To Explain Rulings On Summary Judgment Motions

Wednesday, July 16, 2014

In a unanimous opinion, the Tennessee Supreme Court has determined that the Tennessee Rules of Civil Procedure require trial judges to explain why they are granting or denying a motion for summary judgment before they ask the lawyer for the winning party to prepare a proposed order.

Motions for summary judgment are requests by one or more parties to a lawsuit for the court to rule on the merits of an issue before a case goes to trial. The court can determine prior to the start of a trial that there is no genuine issue of material fact and all or a portion of the case will come to an end.

In the specific case the Court decided today, Mary C. Smith sued UHS of Lakeside, Inc. in the Shelby County Circuit Court following the death of her husband who had been treated at the Lakeside Triage Center in September 2004. UHS filed motions for summary judgment asking the trial court to dismiss Ms. Smith’s lawsuit. During hearings in March 2010 and September 2011, the trial judge orally granted UHS’s motions but did not explain the basis for her decisions. Instead, the trial judge asked UHS’s lawyer to draft orders that provided the legal basis for her decisions. The trial judge signed the orders prepared by UHS’s lawyer despite Ms. Smith’s objections.

Ms. Smith appealed, and the Court of Appeals set aside the summary judgment orders. The Court of Appeals decided the trial court failed to comply with Rule 56 of the Tennessee Rules of Civil Procedure, which requires trial courts to “state the legal grounds” when deciding a motion for summary judgment.

The Supreme Court agreed that the trial court failed to comply with Rule 56. The Court emphasized that deciding a motion for summary judgment is a high judicial function. The requirement that a trial court state its grounds promotes respect for the judicial system by ensuring that a summary judgment decision is the product of the trial court’s own independent analysis.

The Court held that the trial court erred by granting UHS’s motions for summary judgment without providing legal grounds and by asking UHS’s lawyers to supply the orders that articulated the reasons for the court’s decision. The Court concluded the trial court must, “upon granting or denying a motion for summary judgment … state the grounds for its decision before it invites or requests the prevailing party to draft a proposed order.”

In this case, the Court determined the contested orders were not the product of the trial court’s independent judgment, therefore the case was returned to the trial court for further proceedings.


Gas Prices Drop 2.5 Cents In Chattanooga

Average retail gasoline prices in Chattanooga have fallen 2.5 cents per gallon in the past week, averaging $2.07 per gallon on Sunday, according to GasBuddy's daily survey of 170 gas outlets in Chattanooga. This compares with the national average that has fallen 2.5 cents per gallon in the last week to $2.34 per gallon, according to gasoline price website GasBuddy.com. Including ... (click for more)

AEED Receives green|light Certification

AEED, Inc. (Advanced Energy Engineering and Design) completed its green|light certification. A green ribbon cutting ceremony is scheduled for this Thursday at 5 p.m. to celebrate its accomplishment in sustainability. AEED is at 408 McCallie Ave. green|light, a program of green|spaces, supports a business culture of sustainability in Chattanooga. The program supports ... (click for more)

Man With Gun Runs From Police At Hamilton Place Mall; Pushes Shoppers Out Of The Way

A man who was found to be armed with a handgun was chased by police early Saturday afternoon. He pushed shoppers out of the way during the pursuit, which included racing down an escalator.   Erwin J. Rogers, 22, of 6111 Nottingham Dr., is facing multiple charges.    Around 1:50 p.m., Chattanooga Police officers working at the Hamilton Place Mall ... (click for more)

Arrest Made In Sunday Night Murder In LaFayette

An arrest has been made in a murder in LaFayette, Ga., on Sunday night. The Walker County Sheriff's Office and the Georgia Bureau of Investigation are investigating thehomicide that was reported to the Sheriff's Office at about  7:25 p.m.   Law enforcement officers, Walker County Emergency Services and the coroner worked the crime scene on Wheeler Road ... (click for more)

The Tax Assessor's Sneak Attack On Dual Taxpayers

State law requires a reappraisal of properties every four years. The Tax Assessor's Office has always been responsible for that task. A state law was passed several years ago that allows the cost to shift to individual towns and cities that lie within Hamilton County. Just because the tax assessor can legally abuse dual city/county taxpaying property owners doesn't mean he should. ... (click for more)

Roy Exum: Sleep, Kelly’s On Watch

As the most intense week begins in President-elect Donald’s Trump’s ascent to become the most powerful man in the world, it is now strikingly obvious he has surrounded himself with the greatest collection of leaders to ever fill a Presidential cabinet. Each is a proven winner, be it in business, the military, or national affairs. Last week a confirmation hearing were heard for ... (click for more)