Sanders v. Traver

Summary

The Tennessee Supreme Court held that Tennessee Rule of Civil Procedure 6.01 applies to actions under the Governmental Tort Liability Act because the rule defines, rather than extends, the Act's twelve-month statute of limitations. The wrongful-death complaint filed on Tuesday was timely because the one-year anniversary fell on a Sunday and the following Monday was a legal holiday; the court affirmed and remanded.

Holdings

1. Tennessee Rule of Civil Procedure 6.01 applies to actions brought under the Governmental Tort Liability Act because GTLA suits filed in circuit court are ordinarily governed by the Tennessee Rules of Civil Procedure.
2. Rule 6.01 defines, rather than extends, the GTLA's twelve-month statute of limitations.
3. The wrongful-death complaint was timely filed on Tuesday, May 30, 2000, because the one-year anniversary fell on a Sunday and the following Monday was a legal holiday.

Questions Presented

1. Whether Tennessee Rule of Civil Procedure 6.01 applies to actions brought under the Governmental Tort Liability Act.
2. Whether applying Rule 6.01 to a GTLA action impermissibly extends the GTLA's twelve-month statute of limitations.
3. Whether a complaint filed on the first court day after the one-year anniversary, when the anniversary falls on a Sunday followed by a legal holiday, is timely under the GTLA.

Disposition

affirmed