Haley v. University of Tennessee-Knoxville

Summary

The Supreme Court of Tennessee held that filing a claim with the Tennessee Claims Commission activates the waiver provision of Tennessee Code Annotated section 9-8-307(b), even when the claim is later voluntarily withdrawn or dismissed without prejudice. The court also held that Tennessee Supreme Court Rule 23, which authorizes answering certified questions from federal courts, is constitutional and within the court’s inherent judicial power. The court declined to address additional questions outside the scope of the certified question.

Holdings

1. Tennessee Supreme Court Rule 23 is a constitutional and appropriate exercise of the Tennessee Supreme Court's inherent judicial power; answering a certified question is not an adjudicative exercise of the appellate jurisdiction limited by Article VI, section 2 of the Tennessee Constitution.
2. The waiver provision in Tennessee Code Annotated section 9-8-307(b) is activated when the claim is filed with the Tennessee Claims Commission, even if the claimant later voluntarily withdraws the claim or takes a nonsuit before the Commission takes action.
3. The court declined to answer the additional questions because they were outside the scope of the question certified by the federal district court.

Questions Presented

1. Whether Tennessee Supreme Court Rule 23 authorizes the Tennessee Supreme Court to answer a certified question from a federal district court consistently with the Tennessee Constitution.
2. Whether filing a claim with the Tennessee Claims Commission activates the waiver provision of Tennessee Code Annotated section 9-8-307(b) even when the claimant later voluntarily withdraws or takes a nonsuit before the Commission acts.
3. Whether the Tennessee Supreme Court should answer additional questions concerning whether the University is a state officer or official and whether Haley's federal claims arose from the same acts or omissions.

Disposition

other