Anthony Holder v. Shelby County, Tennessee
W2017-00609-COA-R3-CV
| Tenn. Ct. App. | Nov 3, 2017Background
- Decardis Holder (Decedent) was arrested after an April 20, 2013 accident, evaluated as mentally unstable, and placed in the jail’s special “N” unit for unstable inmates.
- Shelby County policy required corrections officers to perform mandatory wellness/safety checks of N-unit inmates at least every 30 minutes.
- Deputy Melvin Moore was assigned to the N-unit on April 21, 2013; he logged a check at 9:16 p.m. but later admitted he did not perform the mandated checks during his eight-hour shift.
- At ~10:14 p.m., after a shift change, Deputy Lorna Morris found Decedent hanging in his cell; Decedent later died from asphyxiation.
- Plaintiff (Anthony Holder, Decedent’s father) sued Shelby County under the Governmental Tort Liability Act (GTLA) alleging county negligence via Deputy Moore’s failures; trial court found Moore’s conduct negligent (not intentional) and entered judgment against Shelby County for $300,000.
- Shelby County appealed only the question whether Moore’s failure to perform checks was negligent or an intentional act (affecting GTLA immunity).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Deputy Moore’s failure to perform required wellness checks was negligent or an intentional act for GTLA purposes | Holder argued Moore’s failure was negligent, removing sovereign immunity and making the County liable | Shelby County argued Moore’s conduct was intentional (e.g., falsifying logs or deliberate omission), fitting GTLA exceptions and preserving immunity | Trial court (affirmed): Moore’s failure was negligent, not intentional; GTLA immunity was removed and County liable |
Key Cases Cited
- Hughes v. Metropolitan Gov’t of Nashville & Davidson Cty., 340 S.W.3d 352 (Tenn. 2011) (distinguishes negligence from intentional torts by focusing on actor’s intent to bring about harm)
- Doyle v. Frost, 49 S.W.3d 853 (Tenn. 2001) (discusses sovereign immunity and the GTLA’s consent-to-be-sued framework)
- Hawks v. City of Westmoreland, 960 S.W.2d 10 (Tenn. 1997) (sovereign immunity principles under Tennessee law)
- Limbaugh v. Coffee Med. Ctr., 59 S.W.3d 73 (Tenn. 2001) (GTLA’s general rule of immunity and statutory scope)
- King v. Ross Coal Co., 684 S.W.2d 617 (Tenn. Ct. App. 1984) (intent requirement distinguishes negligent conduct from intentional torts)