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Tennessee Court Vacates Summary Judgment When Court Failed to Explain Ruling

penWhen a litigant appeals a decision by a lower court in a personal injury or wrongful death action, the appeals court must review the record that was before the lower court, the evidence presented to the judge or jury, and the reasoning behind the court or jury’s decision. In order to conduct an adequate review, the appellate court must have enough information from the lower court to fully understand what happened and how the court reached the outcome that it did. When a lower court fails to do so, the appellate court may be forced to overturn or vacate the decision, as it did in a recent Tennessee Court of Appeals case.

In this negligence action, P.K. brought negligence claims again a medical office for failing to allow for proper service at the office. P.K. alleged negligence and negligent misrepresentation and sought 1.5 million dollars in damages. The defendants immediately moved for summary judgment on the claims, arguing that they had no duty to P.K. to ensure proper service and that P.K. did not experience damages as a result of their actions. The defendants attached several affidavits from various witnesses. P.K. immediately filed a response to the motion, objecting to summary judgment because discovery had not yet occurred, and they could not confirm or dispute the witnesses’ statements because they had not yet had the opportunity to depose them. The court held a hearing to consider the motion for summary judgment and ultimately granted it. P.K. appealed.

In reviewing the hearing transcript, the appeals court noted that the trial court denied P.K.’s request for additional discovery to support his response to the summary judgment motion with very little justification, finding only that it wasn’t necessary. The trial court then concluded that there did not appear to be a duty based on the facts available, and there would be problems with the causation and damages issues, but it did not provide any further information regarding the reasoning behind its decision. The court’s order then summarily stated that the motion for summary judgment was granted. The appeals court noted that Tennessee Rules of Civil Procedure require that a trial court state the legal grounds upon which it is granting or denying a motion and that these grounds be reflected in the order. The appeals court further explained that the basis for such a requirement was precisely so that an appellate court could review the content and the basis for the decision and properly determine whether the decision is valid. Since the trial judge’s oral and written orders did not explain why P.K. failed to show a duty, causation, or damages, the appeals court determined that a review of the decision would be pure speculation and that the trial court was required to revise its order in order to comply with Tennessee Rules. It therefore vacated the lower court’s decision on summary judgment and remanded for a new order.

All litigants are entitled to orders and decisions from the court that adequately explain the basis for the rulings. If you are involved in a lawsuit or legal dispute in which you believe that you are not receiving a fair explanation from the judge, it may be time to consult with an attorney. Tennessee personal injury attorney Eric Beasley has years of experience representing litigants in Tennessee state courts and understands how to work with judges and juries to assert your rights and advocate for the outcome you are entitled to receive. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.

Related Blog Posts:

Tennessee Court Rules that Affidavit is Not Conclusive Evidence of Lack of Material Fact, Tennessee Personal Injury Blog, April 27, 2017.

Tennessee Courts Consider When a Party Can Be Held Liable for an Agent’s Negligence, Tennessee Personal Injury Blog, October 12, 2016.

Do Curbs For Wheelchair Ramps Constitute Dangerous Conditions In Tennessee?, Tennessee Personal Injury Blog, January 27, 2016.