Larry Sneed v. The City of Red Bank, Tennessee

Summary

The Tennessee Supreme Court held that the Tennessee Human Rights Act is an independent and specific statute that governs age-discrimination claims against governmental entities, rather than the Governmental Tort Liability Act. The court further held that the THRA affords plaintiffs a right to a jury trial on such claims filed in chancery court. The court reversed the Court of Appeals, vacated the transfer to circuit court, and remanded the case to the chancery court.

Holdings

1. The Tennessee Human Rights Act is an independent and specific statutory scheme that removes governmental immunity and supplies its own remedies; therefore, the Governmental Tort Liability Act does not govern a THRA age-discrimination claim against a governmental entity.
2. Young v. Davis is overruled to the extent it may be interpreted as holding that the Governmental Tort Liability Act governs all statutory claims against governmental entities.
3. A plaintiff who files a THRA claim in chancery court has a statutory right to a jury trial on disputed material facts under Tennessee Code Annotated section 21-1-103, including when the defendant is a governmental entity.

Questions Presented

1. Whether the Governmental Tort Liability Act governs a Tennessee Human Rights Act age-discrimination claim against a governmental entity.
2. Whether a plaintiff who files a Tennessee Human Rights Act claim against a governmental entity in chancery court has a statutory right to a jury trial.

Disposition

reversed_and_remanded