Published on:

Tennessee Court Denies Claim When Medical Records Suggest No Injury

cell phonePlaintiffs who bring negligence and personal injury claims in court are often focused on gathering all of the evidence possible to show that the defendant is guilty of having caused harm. Often, in these cases, the actual injury suffered by the plaintiff becomes secondary. While proving an injury may seem like a simple matter that is less significant than proving fault, a failure to show an injury can easily end a Tennessee personal injury case. As a recent case before the Tennessee Court of Appeals shows, plaintiffs must be careful not to neglect the importance of showing to a court that the harm they suffered was real.

In this recent prison case, J.M. alleged that he was injured after the power went off at his cell at the Turney Center Industrial Complex. According to J.M., the power went off for several days at the prison, leaving prisoners stuck in darkness. While trying to get out of his top bunk on one of those nights to go to the bathroom, J.M. missed the table on which he normally stepped because he could not see it in the dark, and he fell, hurting his knee and lower back. After discovery, the State of Tennessee moved for summary judgment on the ground that J.M. was not actually injured as a result of the fall. In support of the motion, the State submitted medical records from J.M.’s providers, which showed that J.M. had suffered from knee pain prior to the fall and that neither back nor knee x-rays showed any evidence of a traumatic injury after the fall.

In response to this evidence, the claims commissioner granted the State’s motion for summary judgment, finding that J.M. had not met his burden to show that he experienced an injury or loss as a result of the State’s actions. J.M. appealed this conclusion.

On appeal, J.M. argued that it was wrong for the court to have granted summary judgment to the State. J.M. argued that he was still completing discovery at the time the order on summary judgment came out, and, had he had more time to complete discovery, he would have had more evidence of his injuries. The Court of Appeals evaluated both the existing evidence in the case as well as J.M.’s discovery requests that were pending at the time of the summary judgment order.

The Court of Appeals held that, first of all, the State properly negated J.M.’s claim for damages by providing medical records that showed a lack of injury. The burden then shifted to J.M. to set forth specific facts showing that he had in fact suffered an injury, or at least creating a genuine issue of disputed facts. J.M. failed to do so. Second, the Court of Appeals noted that while J.M. did have outstanding discovery requests at the time of the summary judgment order, none of these requests had anything to do with his injuries, nor would they have had any bearing on the court’s decision. Instead, the requests were related to schedules at the prison, pictures of bunks in the prison, and videos of J.M. interacting with prison officials.

Since the evidence requested in the discovery documents would not have affected the lower court’s decision, even if the information had been obtained prior to the decision, the Court of Appeals held that the lower court did not err in finding that J.M. had not established the existence of an injury in his case. Accordingly, the Court of Appeals affirmed.

While some elements of a negligence claim may be more difficult to prove than others, it is very important that plaintiffs not forget that they have the burden to prove each and every element of their claim. Even if a plaintiff feels that it is self-evident that he or she suffered an injury, a court will expect a plaintiff to provide evidence of that injury. Tennessee personal injury attorney Eric Beasley takes a holistic approach to each negligence case he handles and can help you develop a strategy to prove every element of your personal injury claim. For more information on seeking redress and compensation for your injuries, contact the Law Office of Eric Beasley today at 615-859-2223.

Related Blog Posts:

Tennessee Court Denies Prisoner’s Negligence Claim After Attack, Tennessee Personal Injury Blog, August 8, 2017

Tennessee Court Upholds Conclusion That Officer Was Not Responsible For Accident, Tennessee Personal Injury Blog, July 7, 2017.

Tennessee Court Upholds Exclusion of Evidence for Lack of Relevance, Tennessee Personal Injury Blog, May 2, 2017.