Supplement Record, Motion to

Except as indicated, all indented material is copied directly from the court’s opinion.

Decisions of the Tennessee Supreme Court

Opinions of the Tennessee Court of Appeals

Nelson v. Justice, No. E2020-01172-COA-R3-CV (Tenn. Ct. App. Jan. 24, 2022)


As explained in Tennessee Rule of Appellate Procedures 24(e), the determination of the trial court concerning modification of the record is conclusive “absent extraordinary circumstances.” As our Supreme Court has elucidated:

The procedure for correction or modification of the record reflects the policy of avoiding technicality and expediting a just resolution on the merits by according deference to the trial court’s decision on which matters are properly includable in the record, thereby avoiding additional litigation on that subject alone. The specific purpose of Rule 24 is accommodated as well, since the trial judge is in the best position to determine which matters are necessary to “convey a fair, accurate and complete account of what transpired with respect to those issues that are the bases of appeal.” See also Artrip v. Crilley, 688 S.W.2d 451, 453 (Tenn. [Ct.] App. 1985).

Bradshaw v. Daniel, 854 S.W.2d 865, 868-69 (Tenn. 1993)



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