When a defendant causes a plaintiff’s injury, it is generally understood that the plaintiff can bring a lawsuit against the defendant if there is a basis to do so. For example, if the defendant rear ends the plaintiff in a car accident, the plaintiff may sue for those injuries. Or if a defendant fails to maintain his property safely and knowingly allows dangerous conditions to occur, and a plaintiff is injured, a lawsuit may be possible. In some instances, however, the state of Tennessee wants to prohibit lawsuits for certain public policy purposes. It may do so by making certain defendants immune from liability under certain situations. A recent case before the Tennessee Court of Appeals looks at one of these scenarios.
In this Tennessee personal injury case, F.T. was a prison inmate who was working on a work detail building a bridge. He was pouring concrete for the bridge when some of the concrete spilled into his boots. This lead to chemical burns on F.T.’s feet and permanent scarring. F.T. sued Wayne County, where he was incarcerated, for his injuries, asserting they had been negligent in allowing workers to use concrete without necessary protections. Wayne County immediately moved to dismiss the claim, arguing that F.T. was not allowed to sue for injuries that occurred during work detail under Tennessee law. Specifically, it argued that counties operating prisons and work details were immune from liability under Tennessee statute. The lower court reviewed the statute and agreed, and dismissed the lawsuit.
On appeal, F.T. argued with the lower court’s interpretation of the statute. Tennessee’s statute sets forth two categories of individuals who may be placed on work detail: (1) all prisoners sentenced to the county workhouse and (2) any prisoner sentenced for a period of less than a year to the workhouse or to county jail. The statute further stated that not state or municipal agency or official should be liable to any prisoner who is injured on a work detail. F.T. argued that the immunity provision of the statute should be interpreted only to apply to categories (1) and (2) of prisoners and not all prisoners on work detail. Because he was not one of these two categories, F.T. argued that Wayne County was not immune from liability for his injuries.
The Court of Appeals disagreed. It held that to read the statute in that way required that the language “any prisoner” be ambigous and therefore susceptible to interpretation based on other provisions of the statute. However, in this case, the Court of Appeals held that the statute was not ambiguous at all. Rather, the term “any prisoner” very clearly applied to any prisoner working on a work detail and therefore Wayne County was immune from F.T.’s claims. The Court noted that had Tennessee wanted to limit liability to only prisoners in those first two categories identified in the statute, it could have done so explicitly by making it clear that the immunity was very constricted. Because it did not do so, the court had no choice but to conclude that Tennessee meant to apply immunity in the very broad terms that “any prisoner” suggested. Under these circumstances, the lower court upheld the motion to dismiss and F.T.’s claims against Wayne County were dismissed.
When considering suing a governmental entity or a governmental employee, it always makes sense to check the various immunity provisions that may be available and make sure that none of them apply to the circumstances of your case. Unless truly ambiguous, it is very difficult to overcome the application of immunity in a personal injury case. If you have questions about a particular statute, or are confused as to how immunity might apply in your case, personal injury attorney Eric Beasley can help you evaluate the likelihood of success with your claim. If you have recently been injured and are uncertain about your rights, contact the Law Office of Eric Beasley today at 615-859-2223.
Related Blog Posts:
Sixth Circuit Upholds Claim for Black Lung Benefits, Tennessee Personal Injury Blog, May 30, 2018.
Tennessee Court Finds Homeowner Not Responsible for Worker’s Fall, Tennessee Personal Injury Blog, March 20, 2018.
Tennessee Court Holds That Plaintiff Can Add Comparative Fault Defendants To Case, Tennessee Personal Injury Blog, February 9, 2018.
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