Michelle Rye v. Women's Care Center of Memphis, MPLLC

Summary

The Tennessee Supreme Court overruled Hannan v. Alltel Publishing Co. and adopted a summary judgment standard consistent with Federal Rule of Civil Procedure 56. In this healthcare liability action, the court held that the defendants satisfied their initial burden by demonstrating that the plaintiffs’ evidence was legally insufficient to establish their claims. The court affirmed in part and reversed in part the Court of Appeals and remanded for entry of summary judgment on the claims at issue.

Holdings

1. Hannan v. Alltel Publishing Co. is overruled. When the moving party does not bear the burden of proof at trial, it may satisfy its burden of production either by affirmatively negating an essential element of the nonmoving party's claim or by demonstrating that the nonmoving party's evidence at the summary-judgment stage is insufficient to establish an essential element of the claim or defense.
2. The Ryes could not recover future medical expenses associated with future pregnancies or future blood transfusions because the evidence did not establish that those expenses were reasonably certain to occur; the claimed damages depended on contingencies that had not occurred and might never occur.
3. Ronald Rye's standalone negligent-infliction-of-emotional-distress claim failed because he had no physical injury and did not submit the expert proof required to establish a serious or severe emotional injury.
4. Tennessee law does not recognize disruption of family planning as an independent cause of action or an independent element of damages in this case.
5. The defendants were entitled to summary judgment on Michelle Rye's emotional-distress claim because the evidence at the summary-judgment stage was insufficient to establish the elements necessary for recovery, including a serious or severe emotional injury where the claim was treated as standalone.

Questions Presented

1. Whether Tennessee should overrule the summary-judgment standard adopted in Hannan v. Alltel Publishing Co. and return to the Rule 56 standard reflected in the Celotex trilogy.
2. Whether the evidence established a genuine issue of material fact regarding the reasonable certainty of future medical expenses associated with future pregnancies or emergency blood transfusions.
3. Whether Ronald Rye's standalone negligent-infliction-of-emotional-distress claim could survive summary judgment without expert proof of a serious or severe emotional injury.
4. Whether Tennessee recognizes disruption of family planning as an independent cause of action or an element of damages.
5. Whether Michelle Rye's emotional-distress claim could proceed based on Rh-sensitization and the evidence presented.

Disposition

reversed_and_remanded