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.


GDOL To Host A Recruitment For Aerotek In LaFayette

The Georgia Department of Labor’s (GDOL) LaFayette Career Center will host a recruitment for Aerotek, a staffing agency, to hire 20 production workers and 20 welders to work in Walker County. The recruitment will be held on  Tuesday, April 11 , from  10 a.m. to 1 p.m.  at the career center at 200 W. Villanow St. in LaFayette. Due to U.S. Occupational ... (click for more)

Chattanooga Chamber Leads State In tnAchieves Mentor Recruitment

The Chattanooga Chamber's staff led Tennessee in the goal to recruit mentors for this year's tnAchieves mentoring program. In its third year, the program pairs high school seniors with professionals and other volunteers to ease the transition from high school to college. Mentors began meeting with their students this month. With a goal of 387 volunteers, Hamilton County signed up ... (click for more)

State Says "Beef" Between 2 Bloods Gangs Started Over A Female And Led Eventually To Shootings At College Hill Courts

The state presented testimony on Monday about a feud between two Bloods gangs that allegedly eventually led to a 16-year-old shooting up a unit at College Hill Courts - killing one woman, injuring another, leaving a child paralyzed and injuring a member of the other Bloods gang. A city police gang expert said the bitter rift between the Athens Park Bloods based on the Southside ... (click for more)

Walker County To Raise Water, Sewer Rates To Improve Aging Infrastructure

 The board of directors for the Walker County Water & Sewerage Authority (WCWSA) has granted approval for the utility to move forward with a base rate increase to address aging infrastructure concerns.   Starting this summer, WCWSA will begin replacing older galvanized pipe. These older water mains will be upgraded from two-inch galvanized pipe to six-inch high-pressure ... (click for more)

Slaxxon Regret - And Response

Back in the seventies my three oldest brothers had a buddy named Steve Slack. “Slack” was a star soccer player at Baylor and he grew up on Lookout Mountain, which is where I grew up. He and Jimmy, Henry and Bill went to the University of Virginia where they were roommates in an old, beat up house that was painted pink. Naturally, the place became known as the “Pink Palace” but lest ... (click for more)

Roy Exum: Oh Yes, I Loved West

One of my most beloved friends died early Saturday morning at the age of 67. Then again, West Oehmig’s only brother – King – died a couple of years ago at 63 so it wasn’t by happenstance I remembered Abraham Lincoln’s famous line: “In the end, it’s not the years in your life that count, it’s the life in your years.” Here are two brothers who lived larger than any other pair I can ... (click for more)