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.


Transportation Coalition Of Tennessee Announces Inaugural Members

The Transportation Coalition of Tennessee announced on Thursday that 30   organizations, including the Nashville Area Chamber of Commerce, AARP and the Tennessee County Commissioners Association, have joined the coalition in support of its mission to educate the public and work with state legislators to reform Tennessee’s transportation fund. The statewide coalition formed ... (click for more)

Baker Donelson Ranked 30th In 6th Consecutive Year On Fortune's 100 Best Companies To Work For List

The law firm of Baker Donelson has once again been named one of Fortune's 100 Best Companies to Work For. In its sixth consecutive year to be included, Baker Donelson is ranked 30th, earning its highest ranking yet and its second consecutive year as the highest ranked law firm on the prestigious list, which recognizes companies that have exceptional workplace cultures.  ... (click for more)

Judge Orders Cortez Sims Tried As Adult After Emotional Testimony At Juvenile Court In Shooting Of 4

Juvenile Court Judge Rob Philyaw on Thursday morning ordered that 17-year-old Cortez Sims be tried as an adult in a College Hill Courts shooting that left one woman dead, a toddler paralyzed, and two others wounded. The order was given after emotional testimony from two of the victims in the Jan. 7 early morning mass shooting at 773 W. Main St. Bianca Horton and Marcell "Baby ... (click for more)

EPB Lays Out Plans To Provide All Of Bradley County With High-Speed Internet, TV Service; Cost Is Up To $60 Million

In what was hailed as a big win for rural Bradley Countians, EPB officials laid out a plan Thursday night to reach the community with currently unavailable high-speed internet. EPB CEO Harold DePrist told a capacity crowd at the Bradley County Courthouse that the expansion would serve roughly 1,000 people, about 800 of whom have no current option other than dial-up. The ... (click for more)

How To Kill Small Business And Education In Chattanooga

   I would just like to say that the weathermen of Chattanooga have done something I thought only a union could do. They have undone all the economic good that VW has brought to our area. Their erroneous and hysteric forecasts are in my opinion purposefully done to benefit their corporate owners so viewers and readers flock to their felonious broadcasts and yellow ... (click for more)

Roy Exum: America’s Newest Darling

Minutes after I read a letter on Rebekah Gregory’s Facebook page yesterday, I was mere seconds from summoning the marching band, our prancing elephants, and the flag-bearers so we could rightfully induct this dazzling survivor of the Boston Marathon blast into my personal Hall of Fame. I do that, you know, when I see everyday people display courage, kindness, guts, brilliance, ... (click for more)