Declaratory Judgments
Declaratory Judgments, Generally
Except as indicated, all indented material is copied directly from the court’s opinion.
Opinions of the Tennessee Supreme Court
Phillips v. Hatfield, 624 S.W.3d 464, 473–74 (Tenn. 2021).
The case before us is a declaratory judgment action. See generally Tenn. Code Ann. §§ 29-14-102 & -103 (2012) (empowering a court to declare parties’ rights under instruments such as a deed). It was tried without a jury before the Sullivan County Chancery Court. We review a non-jury case de novo on the record with a presumption of correctness *474 as to the findings of fact of the trial court, unless the evidence preponderates otherwise. Kelly v. Kelly, 445 S.W.3d 685, 691–92 (Tenn. 2014); Rogers v. Louisville Land Co., 367 S.W.3d 196, 204 (Tenn. 2012); Tenn. R. App. P. 13(d). For evidence to preponderate against the trial court’s findings of fact, the evidence must support another finding of fact with greater convincing effect. C-Wood Lumber Co. v. Wayne Cnty. Bank, 233 S.W.3d 263, 272 (Tenn. Ct. App. 2007); Realty Shop, Inc. v. RR Westminster Holding, Inc., 7 S.W.3d 581, 596 (Tenn. Ct. App. 1999). Because the trial court is able to observe witnesses as they testify, appellate courts afford deference to the trial court’s credibility assessments of live, in-court testimony. Kelly, 445 S.W.3d at 692; Wells v. Tenn. Bd. of Regents, 9 S.W.3d 779, 783–84 (Tenn. 1999). On the other hand, when evaluating documentary proof, the ability of an appellate court to assess the evidence is the same as that of the trial court, and thus there need be no deference afforded to the trial court’s assessment. Kelly, 445 S.W.3d at 693; Wells, 9 S.W.3d at 783–84. Of course, we review questions of law de novo with no presumption of correctness. Kelly, 445 S.W.3d at 692; Rogers, 367 S.W.3d at 204.
Tennessee Farmers Mutual Ins. Co. v. DeBruce, No. E2017-02078-SC-R11-CV, 586 S.W.3d 901, 905 (Tenn. 2019).
The determination that [a person making a personal injury claim] was not a necessary party to the declaratory judgment action [seeking to determine whether DeBruce had liability insurance in place at the time claim arose] was also within the trial court’s discretion, and we will uphold the trial court’s decision unless we determine that the trial court abused its discretion. Timmins v. Lindsey, 310 S.W.3d 834, 839 (Tenn. Ct. App. 2009) (citations omitted).
“A trial court abuses its discretion when it causes an injustice by applying an incorrect legal standard, reaching an illogical decision, or by resolving the case ‘on a clearly erroneous assessment of the evidence.’ ” Henderson, 318 S.W.3d at 335 (quoting Lee Med., Inc. v. Beecher, 312 S.W.3d 515, 524 (Tenn. 2010)). We presume that the trial court’s discretionary decision is correct, and we review the evidence in the light most favorable to the trial court’s decision. Id. (quoting Overstreet v. Shoney’s, Inc., 4 S.W.3d 694, 709 (Tenn. Ct. App. 1999) and citing Keisling v. Keisling, 196 S.W.3d 703, 726 (Tenn. Ct. App. 2005)).
Opinions of the Tennessee Court of Appeals
Brock v. Eick, No. E2023-00021-COA-R3-CV, p. 5-6 (Tenn. Ct App. Oct. 27, 2023).
Generally, the trial court has discretion to determine who should be made parties to proceedings for declaratory judgment as well as whether to grant or deny a declaratory judgment. Huntsville Utility, 839 S.W.2d at 399; see Powers, 54 S.W.2d at 938. Absent an abuse of that discretion, a declaration should not be disturbed on appeal. Huntsville Utility, 839 S.W.2d at 399 (citing Southern Ry. Co. v. Atlantic Coast Line R. Co., 209 Tenn. 177, 182, 352 S.W.2d 217, 219 (1961); Love v. Cave, 622 S.W.2d 52, 55 (Tenn. Ct. App. 1981)).
Timmins v. Lindsey, 310 S.W.3d 834, 839 (Tenn. Ct. App. 2009).
Neff v. Wood, No. M2020-00748-COA-R3-CV (Tenn. Ct. App. Jan. 27, 2022) (court granted declaratory relief in dispute over easement).
It is within a court’s discretion “to fashion an appropriate equitable remedy given the particular circumstances of each case.” Hixson v. Am. Towers, LLC, 593 S.W.3d 699, 718 (Tenn. Ct. App. 2019). We will not disturb the court’s declaratory relief absent an abuse of discretion. See Lee Med. Inc., 312 S.W.3d at 524.
