Sanctions
Sanctions Other Than Discovery Sanctions
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
Justice v. Nelson, No. E2022-01540-COA-R3-CV, p. 20-21 (Tenn. Ct. App. Oct. 6, 2023).
We review a trial court’s ruling on a Rule 11 motion under an abuse of discretion standard. Hooker v. Sundquist, 107 S.W.3d 532, 535 (Tenn. Ct. App. 2002). An abuse of discretion occurs when the decision of the lower court has no basis in law or fact and is therefore arbitrary, illogical, or unconscionable. Id. (citing State v. Brown & Williamson Tobacco Corp., 18 S.W.3d 186, 191 (Tenn. 2000)). Our review of Rule 11 decisions is governed under this deferential standard since the question of whether a Rule 11 violation has occurred requires the trial court to make highly fact-intensive determinations regarding the reasonableness of the attorney’s conduct. Id. We review the trial court’s findings of fact with a presumption of correctness. Id.; Tenn. R. App. P. 13(d).
Doe v. Rosdeutscher, No. M2022-00834-COA-R3-CV, p. 8 (Tenn. Ct. App. April 27, 2023).
We review a trial court’s ruling on a Rule 11 motion under an abuse of discretion standard. Hooker v. Sundquist, 107 S.W.3d 532, 535 (Tenn. Ct. App. 2002). “An abuse of discretion occurs when the decision of the lower court has no basis in law or fact and is therefore arbitrary, illogical, or unconscionable.” Id. (citing State v. Brown & Williamson Tobacco Corp., 18 S.W.3d 186, 191 (Tenn. 2000)).
Goetz v. Autin, No. W2022-00393-COA-R3-CV, p. 25 (Tenn. Ct. App. Mar. 17, 2023).
We review a trial court’s ruling on a Rule 11 motion for sanctions for an abuse of discretion. Id. at 200 (citation omitted). “An abuse of discretion occurs when the decision of the lower court has no basis in law or fact and is therefore arbitrary, illogical, or unconscionable.” Id. (citations omitted). This deferential standard governs our review of this issue because “the question of whether a Rule 11 violation has occurred requires the trial court to make highly fact-intensive determinations regarding the reasonableness of the attorney’s conduct.” Id. (citation omitted). We review the trial court’s factual findings with a presumption of correctness. Id.; Tenn. R. App. P. 13(d).
Christy v. Christy, No. M2021-00192-COA-R3-CV, p. 7 (Tenn. Ct. App. Mar. 30, 2022).
“Appellate courts review a trial court’s decision to impose sanctions and its determination of the appropriate sanction under an abuse of discretion standard.” Alexander v. Jackson Radiology Assocs., P.A., 156 S.W.3d 11, 14 (Tenn. Ct. App. 2004) (citing Lyle v. Exxon Corp., 746 S.W.2d 694, 699 (Tenn. 1988)). L
