Brenda Benz-Elliott v. Barrett Enterprises, LP et al.

Summary

The Tennessee Supreme Court held that determining the applicable statute of limitations requires identifying the gravamen of each claim, considering both its legal basis and the injury for which damages are sought. It concluded that the plaintiff’s claim concerning the omitted access-strip reservation was principally for breach of contract and therefore subject to Tennessee’s six-year limitations period for contract actions, rather than the three-year period for injuries to real property. The court reversed the Court of Appeals and remanded for consideration of the defendants’ remaining appellate issues.

Holdings

1. When a complaint alleges more than one claim, a court must identify the gravamen of each claim separately rather than determine a single gravamen for the complaint as a whole. The court must consider both the legal basis of the claim and the type of injury for which damages are sought.
2. Benz-Elliott's claim was governed by the six-year statute of limitations for actions on contracts not otherwise expressly provided for, Tenn. Code Ann. § 28-3-109(a)(3), not the three-year statute of limitations for injuries to personal or real property.

Questions Presented

1. What analysis should a court use to determine the applicable statute of limitations when a complaint alleges multiple claims?
2. Whether Benz-Elliott's prevailing claim was governed by Tennessee's three-year statute of limitations for injuries to personal or real property or its six-year statute of limitations for contracts not otherwise expressly provided for.

Disposition

reversed_and_remanded