According to Tennessee Court, City Governments Mostly Immune From Liability for Prison Work Details

Tennessee’s Governmental Tort Liability Act governs how and when government agencies can be held liable for torts that may occur on their property or that have been committed by their employees. Under the GTLA, government agencies are generally immune from suit when injuries result from the government doing its job, unless certain exceptions apply. One of those exceptions is for negligent acts or omissions of government employees acting within the scope of their employment. Recently, a prisoner brought a Tennessee injury case to determine whether cities and counties in Tennessee are liable for injuries that occur on prisoner work details.

In this recent case, S.E. was serving a sentence at the Coffee County jail in Tennessee, where he was assigned to a work detail that involved cleaning up public properties in the City of Manchester, Tennessee. S.E. fell off a pickup truck while on the job and injured his head. He sued both the City of Manchester and Coffee County for his injuries, medical expenses, and damages. Coffee County settled with S.E., but S.E. continued to pursue claims against the City of Manchester. In response, the City moved to dismiss S.E.’s complaint, arguing that it was immune from liability under the GTLA. The trial court agreed and dismissed the case. S.E. appealed.

On appeal, S.E. argued that under the exception to the GTLA for negligent acts by employees, the City was not immune from liability because a police officer with the City of Manchester was supervising the work detail at the time. The City countered by pointing to Tennessee Statute 41-2-123(d)(2), which provides that states, municipalities, and their employees are not liable to prisoners or a prisoner’s family for death or injuries sustained on work detail, other than for medical treatment due to the injury while the prisoner is in prison. Here, medical treatment had been provided to S.E. after his injury, and the City took the position that it was not liable for any additional claims. In response, S.E. argued that the GTLA took precedence over the statute identified by the City. After reviewing the two statutes, the Court of Appeals disagreed.

The Court of Appeals turned to Tennessee’s Rules of Statutory Construction, which hold that when there are general provisions addressing an issue and specific provisions addressing a subset of that issue, the special provision is deemed to be an exception to the general provision if the two are inconsistent. Here, under the GTLA, government employers may generally be held liable for the negligent acts of their employees within the scope of employment. However, under 41-2-123(d)(2), government employers and employees are not liable for injuries that occur while a prisoner is on work detail, beyond being required to provide medical treatment to the prisoner if he is still incarcerated after the injury. The Court of Appeals concluded that this specific statute was an exception to the GTLA and allowed the City to retain immunity in this situation for all but S.E.’s medical treatment during his time in prison. Since S.E. was provided with medical treatment, and the City did pay those medical bills, the Court of Appeals affirmed the conclusion that the City of Manchester had no further liability for S.E.’s injuries.

Suing a governmental agency can be a very complicated endeavor. Even when you are injured by the negligent acts of an employee, plaintiffs must still prove that the negligent acts occurred in the scope of employment and that no other exceptions, such as the special exception identified in this case, apply. Tennessee premises liability attorney Eric Beasley can guide you in evaluating any immunity problems that you are likely to encounter and help you determine whether any exemptions may exist. 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:

Immunity from Tennessee Governmental Tort Immunity Act for Discretionary Actions, Tennessee Personal Injury Blog, December 20, 2016.

Immunity From Personal Injury Claims for Contractors – Black v. Dixie, Tennessee Personal Injury Blog, September 7, 2016.

Immunity from Personal Injury for Tennessee Ski Resorts, Tennessee Personal Injury Blog, April 27, 2016.

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