Justia Government & Administrative Law Opinion Summaries

Employee injured his back while working for Employer. Employee and the Department of Labor and Workforce Development (Department) agreed upon a settlement that provided for a lump sum payment to Employer for his injuries. The settlement and SD-1 form were signed by Employee and both parties' attorneys. Two years later, Employee filed a petition to set aside the settlement. The trial court granted Employee's petition. The Special Workers' Compensation Appeals Panel vacated the trial court's judgment on a procedural issue, finding the SD-1 form was not "fully completed." The Supreme Court reversed the judgments of the Panel and of the trial court and dismissed Employee's petition, holding (1) when the Department approves a settlement, it implicitly approves the accompanying SD-1 form, and a court has no authority to set the settlement aside based on its independent finding that the SD-1 form was not "fully completed"; and (2) the evidence preponderated against the trial court's finding that Employee was not represented by counsel, and the court erred in granting relief based on Tenn. R. Civ. P. 60.02(5) as well as its inherent authority. View "Furlough v. Spherion Atlantic Workforce, LLC" on Justia Law

Plaintiff was a tenured teacher who worked for Defendant, the Memphis City Schools Board of Education. After Plaintiff requested and was granted a substantial amount of sick leave but failed to return from that sick leave, Defendant dismissed Plaintiff without providing her with written charges or an opportunity for a hearing. Plaintiff filed a complaint alleging that her dismissal violated the Tennessee Teacher Tenure Act and her constitutional due process rights. The trial court granted Plaintiff's motion for partial summary judgment and awarded Plaintiff's reinstatement, back pay, compensatory damages for the actual harm she suffered, and attorney's fees. The court of appeals vacated the grant of summary judgment. The Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court, holding (1) although a tenured teacher's failure to return from sick leave may constitute cause for termination, there is no statute authorizing a board of education to deem it a constructive resignation or a forfeiture of tenure; and (2) accordingly, Defendant violated Plaintiff's rights under the Tenure Act and her constitutional due process rights. View "Thompson v. Memphis City Schs. Bd. of Educ." on Justia Law

After injuring another student, a public high school student was cited for an infraction of the student conduct rule proscribing reckless endangerment. The principal's decision to suspend the student for ten days was upheld by a hearing board and the director of schools. Thereafter, the student and his family sought judicial review of the disciplinary decision. The trial court concluded (1) the school officials had violated the student's procedural due process rights because one official had performed both prosecutorial and decision-making functions and because this official was biased against the student; and (2) the evidence did not support the conclusion that the student's conduct amounted to reckless endangerment. Accordingly, the court directed the school system to expunge the student's record and awarded the student and his family attorneys' fees and costs. The court of appeals reversed. The Supreme Court affirmed, holding (1) the student received the required due process protections before he was suspended; (2) the hearing process after the student was suspended as applied did not render the proceedings fundamentally unfair; and (3) the court of appeals did not err by overturning the trial court's conclusion that the school officials acted arbitrarily and illegally. View "Heyne v. Metro. Nashville Bd. of Pub. Educ." on Justia Law

An employee filed a request for assistance with the Tennessee Department of Labor after she was injured at her workplace. After approximately six months of inaction by the Department, the employee filed a complaint for workers' compensation benefits against her employer in the circuit court. The employer responded with a motion to dismiss asserting that the trial court lacked subject matter jurisdiction because the parties had not participated in the benefit review conference process. The trial judge did not dismiss the complaint but ordered the case to be held in abeyance pending further orders of he court. The Supreme Court reversed the judgment of the trial court and dismissed the employee's complaint with prejudice, holding that the trial court did not have subject matter jurisdiction of the case because the employee did not exhaust the benefit review conference process before filing suit as required by Tenn. Code Ann. 50-6-203. View "Chapman v. Davita, Inc." on Justia Law

Jefferson County enacted a comprehensive zoning ordinance limiting the use of certain property, including Plaintiff's property, to agricultural purposes. Before the passage of the ordinance, Plaintiff undertook various activities designed to establish business operations for its property. When the County issued a stop work order, Plaintiff, without first receiving a decision from the County's board of zoning appeals, filed a declaratory judgment action arguing that the portion of the property not previously subject to zoning qualified as a pre-existing non-conforming use. The trial court (1) concluded Plaintiff was not required to exhaust its administrative remedies, and (2) ruled that the business activities on the property qualified for protection under Tenn. Code Ann. 31-7-208. The court of appeals set the judgment aside, holding that Plaintiff had failed to exhaust its administrative remedies. The Supreme Court reversed and reinstated the judgment of the trial court, holding (1) the trial court did not err by ruling that Plaintiff was not required to exhaust the administrative remedies; and (2) the evidence did not preponderate against the trial court's finding that Plaintiff had established operations sufficient to qualify for protection under section 13-7-208. View "Ready Mix, USA, LLC v. Jefferson County" on Justia Law

Employee was discharged after she filed complaints with the Equal Employment Opportunity Commission and a lawsuit against Employer alleging employment discrimination. Employee appealed the termination to the Metro Civil Service Commission (Commission) and eventually settled the appeal, receiving backpay and other consideration in exchange for her agreement not to accept future employment with the agency that discharged her. Employee subsequently filed a complaint against Employer alleging violations of the Civil Rights Act and Age Discrimination in Employment Act. The trial court granted summary judgment in favor of Employer, reasoning that Employee could not establish her termination constituted an adverse employment action because she had accepted backpay and agreed not to be reinstated as part of the settlement of her Commission appeal. The court of appeals affirmed. The Supreme Court reversed, holding that Employee's acceptance of the settlement did not preclude her from establishing that her termination constituted an adverse employment action for purposes of her federal retaliatory discharge claims. View "Perkins v. Metro. Gov't of Nashville & Davidson County" on Justia Law

The trial court awarded workers' compensation benefits to an injured lineman who had violated a rule requiring the use of protective gloves while in a bucket lift. The employer appealed, contending that the statutory defenses of willful misconduct and, more particularly, the willful failure or refusal to use a safety appliance or device precluded recovery. The Supreme Court reversed the judgment of the trial court and dismissed the case, holding that because the evidence established that the employee admitted his knowledge of a regularly enforced safety rule, understood the rationale for the rule, and willfully failed to comply, the injuries he suffered because of the rule violation were not compensable.

The Tennessee Board of Medical Examiners suspended Dr. Joseph Rich's medical license for one year and imposed other conditions after finding that, among other things, the physician had violated Tenn. Code Ann. 63-6-214(b)(1)(4) and (12). The chancery court affirmed the Board's judgment. The court of appeals reversed because the Board failed to articulate the applicable standard of care in its deliberations. The Supreme Court (1) held that the Board was required by Tenn. Code Ann. 63-6-214(g) to articulate the applicable standard of care in its deliberations; (2) vacated the ruling of the trial court to the extent that it affirmed the Board's decision that Rich had violated sections 63-6-214(b)(1)(4) and (12); (3) vacated the judgment of the court of appeals to the extent it reversed the Board's findings that Rich violated sections 63-6-214(b)(1)(4) and (12); and (4) rather than reversing the Board's findings of violations, remanded the matter to the Board with instructions to conduct deliberations based on the existing record and articulate the applicable standard of care as required by the statute.

Employee suffered a work-related injury and sought benefits. The benefit review conference at the Department of Labor and Workforce Development (DOL) ended in an impasse after a dispute about the degree of Employee's medical impairment. Employee filed suit. Subsequently, Employer filed an application for medical impairment rating (MIR) with the DOL, seeking the appointment of an independent medical examiner pursuant to Tenn. Code Ann. 50-6-204(d)(5). The trial court granted Employee's motion to quash the MIR, holding that the statute was established for the purpose of resolving workers' compensation claims while the claim was before an administrative body, and therefore, DOL had relinquished jurisdiction when the benefit review process reached an impasse. The trial court then adopted the higher of the disputed impairment ratings. The Supreme Court vacated the judgment of the trial court, holding (1) the constitutional separation of powers question was not properly presented, argued, or litigated before the trial court; and (2) whether the Employer may attempt to resolve the dispute of degree of medical impairment by seeking the opinion of an independent medical examiner pursuant to the statute was an issue for the Employee, Employer, and Attorney General to address on remand.

While Alicia Howell worked on an assembly production line at Nissan North America, she was diagnosed with bilateral carpal tunnel syndrome. After surgery, Howell and Nissan settled Howell's workers' compensation claim for her carpal tunnel injuries. When Howell attempted to return to work, she was told she would be returning to the fast-paced assembly line. Howell resigned and was hired at minimum wage for a temporary staffing agency. Howell then filed a petition for reconsideration of her earlier settlement. The trial court held that Howell was eligible for reconsideration of her workers' compensation benefits because she did not have a meaningful return to work and awarded her a twenty-five percent permanent partial disability rating to each upper extremity. The Special Workers' Compensation Appeals Panel reversed. The Supreme Court reversed the judgment of the appeals panel and reinstated the judgment of the trial court, holding (1) the appeals panel erred in holding that Howell had a meaningful return to work and her decision to resign rather than returning to work was unreasonable, and (2) the trial court's award was not excessive.