Almond Reid v. Nigel Reid, Sr., 388 S.W.3d 292

Almond Reid owns an apartment complex in Morristown and rented a unit to his brother Nigel Reid Sr.
Nigel allegedly failed to pay rent, prompting a forcible entry and detainer action seeking possession and unpaid rent.
General Sessions Court awarded Landlord $1,400 and issued a writ of possession.
Nigel appealed to the Circuit Court for a trial de novo under Tenn. Code Ann. § 27-5-108.
The Circuit Court later awarded Landlord $2,150 in unpaid rent and a writ of possession.
On appeal, the record lacked a transcript or statement of the evidence, so review was limited and the Circuit Court’s judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of appellate record for review	Reid argues the record is insufficient to challenge the trial court's findings	Reid contends the record supports the circuit court's judgment despite the sparse transcript	Record inadequate; court presumes sufficiency and affirms the judgment

Nashville Ford Tractor, Inc. v. Great Am. Ins. Co., 194 S.W.3d 415 (Tenn. Ct. App. 2005) (standard for reviewing factual findings when record is incomplete)
Taylor v. Allstate Ins. Co., 158 S.W.3d 929 (Tenn. Ct. App. 2004) (limits of appellate review; need adequate evidentiary record)
Dorrier v. Dark, 537 S.W.2d 888 (Tenn. 1976) (presumption of factual findings in absence of record)
Realty Shop, Inc. v. RR Westminster Holding, Inc., 7 S.W.3d 581 (Tenn. Ct. App. 1999) (appellate review constrained by record completeness)