Post-Trial and Post-Judgment Matters
Rule 54.02 Motion (To Reconsider Entry of Summary Judgment)
Except as indicated, all indented material is copied directly from the court’s opinion.
Decisions of the Tennessee Supreme Court
Decisions of the Tennessee Court of Appeals
Doe v. Bellevue Baptist Church, No. W2022-01350-COA-R3-CV, p. 4-5 (Tenn. Ct. App. Nov. 7, 2023).
As noted above, the Parents challenge the propriety of the trial court’s dismissal of their NIED claims upon Bellevue’s motion to dismiss for failure to state a claim, while also raising the question of whether the trial court erred in denying their motion seeking relief from the dismissal order and, alternatively, to amend their complaint. Whereas we review the first of these issues de novo, with no presumption of correctness, we review the latter matters for an abuse of discretion. See Khan v. Regions Bank, 572 S.W.3d 189, 194 (Tenn. Ct. App. 2018) (“A trial court’s decision to grant a Rule 12.02(6) motion to dismiss is a question of law that we review de novo with no presumption of correctness.”); Discover Bank v. Morgan, 363 S.W.3d 479, 487 (Tenn. 2012) (noting that motions to revise under Rule 54.02 and motions for relief under Rule 60.02 are both reviewed for an abuse of discretion); Pratcher v. Methodist Healthcare Memphis Hosps., 407 S.W.3d 727, 741 (Tenn. 2013) (“Trial courts have broad authority to decide motions to amend pleadings and will not be reversed absent an abuse of discretion.”). Regarding Bellevue’s motion to dismiss, we note that “[a] Rule 12.02(6) motion challenges only the legal sufficiency of the complaint, not the strength of the plaintiff’s proof or evidence.” Webb v. Nashville Area Habitat for Humanity, Inc., 346 S.W.3d 422, 426 (Tenn. 2011). The resolution of the motion is determined by an examination of the pleadings alone. Id. When a trial court decides whether to grant leave to amend a complaint, pertinent factors to consider include whether there has been an undue delay in filing and whether there is futility of amendment. Kincaid v. SouthTrust Bank, 221 S.W.3d 32, 42 (Tenn. Ct. App. 2006).
Infinity Homes, Inc. v. Horizon Land Title, Inc., No. M2022-00829-COA-R3-CV, p. 5-6 (Tenn. Ct. App. June 8, 2023).
On appeal, this Court reviews a trial court’s Rule 54.02 certification of a judgment as final using a dual standard of review. King v. Kelly, No. M2015-02376-COA-R3-CV, 2016 WL 3632761, at *3 (Tenn. Ct. App. June 28, 2016); Brown v. John Roebuck & Assocs., Inc., No. M2008-02619-COA-R3-CV, 2009 WL 4878621, at *5 (Tenn. Ct. App. Dec. 16, 2009). The initial determination of whether a particular order disposes of a distinct and separable “claim” that is subject to Rule 54.02 certification is a question of law, which we review de novo. Ingram, 379 S.W.3d at 238; Brown, 2009 WL 4878621, at *5. If the order properly disposes of an entire claim or party, this Court must then determine whether “there is no just reason for delay” within the meaning of Rule 54.02. The trial court’s determination as to this issue is reviewed under an abuse of discretion standard. King, 2016 WL 3632761, at *3; Ingram, 379 S.W.3d at 238.
The Wise Group, Inc. v. Holland, No. M2020-01646-COA-R3-CV, p. 4-5 (Tenn. Ct. App. Mar. 31, 2023).
In general, we review a trial court’s ruling on a Rule 54.02 motion applying an abuse of discretion standard. Id. at 487; Harris v. Chern, 33 S.W.3d 741, 746 (Tenn. 2000). Under that standard, we consider whether “the trial court applied incorrect legal standards, reached an illogical conclusion, based its decision on a clearly erroneous assessment of the evidence, or employed reasoning that causes an injustice to the complaining party.” Discover Bank, 363 S.W.3d at 487 (quoting State v. Jordan, 325 S.W.3d 1, 39 (Tenn. 2010)). We will uphold the trial court’s ruling as “long as reasonable minds can disagree as to [the] propriety of the decision made.” Eldridge v. Eldridge, 42 S.W.3d 82, 85 (Tenn. 2001) (quoting State v. Scott, 33 S.W.3d 746, 752 (Tenn. 2000)).
Waddell v. Waddell, No. W2020-00220-COA-R3-CV, p. 11-12 (Tenn. Ct. App. Mar. 14, 2023).
This Court reviews a trial court’s ruling on a motion to revise under an abuse of discretion standard. Harris, 33 S.W.3d at 746 (citing Donnelly v. Walter, 959 S.W.2d 166, 168 (Tenn. Ct. App. 1997)); see also Discover Bank, 363 S.W.3d at 487. As the Tennessee Supreme Court has explained,
The abuse of discretion standard does not allow the appellate court tosubstitute its judgment for that of the trial court, Williams v. Baptist Mem’l Hosp., Myint v. Allstate Ins. Co., 970193 S.W.3d 545, 551 (Tenn. 2006); S.W.2d 920, 927 (Tenn. 1998), and we will find an abuse of discretion only if the court “applied incorrect legal standards, reached an illogical conclusion, based its decision on a clearly erroneous assessment of the evidence, or employ[ed] reasoning that causes an injustice to the complaining party.” Konvalinka v. Chattanooga-Hamilton Cnty. Hosp. Auth., 249 see also Lee Med., Inc. v. Beecher, 312S.W.3d 346, 358 (Tenn. 2008); S.W.3d 515, 524 (Tenn. 2010).
Wright ex rel. Wright v. Wright, 337 S.W.3d 166, 176 (Tenn. 2011).
Luna Law Group, PLLC v. Roberts, No. M2021-00699-COA-R3-CV, p. 5 fn. 3 (Tenn. Ct. App. July 27, 2022).
As this Court has explained before, “[a] trial court’s ruling on a Rule 54.02 motion to revise is reviewed for an abuse of discretion standard.” Johnson v. Tanner-Peck, L.L.C., No. W2009-02454-COA-R3-CV, 2011 WL 1330777, at *8 (Tenn. Ct. App. Apr. 8, 2011). “When reviewing a discretionary decision, the trial court’s findings of fact are reviewed de novo, and they are presumed correct unless the preponderance of the evidence is otherwise. The trial court’s legal conclusions, however, are reviewed de novo with no presumption of correctness.” Id. (citing Lee Med., Inc. v. Beecher, 312 S.W.3d 515, 525 (Tenn. 2010)).
Guo v. Rogers, No. M2020-01209-COA-R3-CV, p. 16-17 (Tenn. Ct. App. Apr. 26, 2022).
Whether to grant Plaintiff’s motion to amend [the entry of summary judgment against him] was within the Trial Court’s discretion. We find that the Trial Court, in denying Plaintiff’s motion to amend, did not apply an incorrect legal standard; did not reach an illogical or unreasonable decision; and did not base its decision on a clearly erroneous assessment of the evidence. We find further that the factual basis for the Trial Court’s decision to deny Plaintiff’s motion to amend is properly supported by evidence in the record; that the Trial Court properly identified and applied the most appropriate legal principles applicable to the decision; and the Trial Court’s decision was within the range of acceptable alternative dispositions. In short, we discern no abuse of discretion by the Trial Court in its declination to grant Plaintiff’s motion to amend.
