Charles D. Sprunger v. Cumberland County, TN Sheriff's Office
E2016-02572-COA-R3-CV
| Tenn. Ct. App. | Jul 27, 2017Background
- In 2008 child pornography was discovered on Charles Sprunger’s home computer; Detective John Haynes seized the computer and later obtained a forfeiture warrant for Sprunger’s house under Tennessee forfeiture statutes.
- Haynes served a Notice of Property Seizure but failed to give statutorily required information about how Sprunger could contest the seizure.
- Sprunger was convicted of possession of child pornography and the State sought judicial forfeiture; a foreclosure sale occurred and $31,606.26 in excess proceeds were deposited with the court clerk pending resolution.
- The Tennessee Supreme Court vacated the forfeiture in State v. Sprunger, holding the State had not complied with procedural notice requirements; the excess proceeds were awarded to Sprunger.
- Sprunger then sued the Cumberland County Sheriff’s Office under Tenn. Code Ann. § 40-33-215 for a “bad faith seizure,” seeking fees and monetary damages; the trial court granted summary judgment for the County, finding no evidence of intentional misconduct and that Haynes had a reasonable legal basis to seize.
- On appeal the Court of Appeals affirmed: it waived the County’s statute-of-limitations argument, but held Haynes did not act in bad faith under § 40-33-215 because procedural errors alone, without knowing misconduct or indifference, do not establish bad faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness (statute of limitations) | Sprunger: claim accrued when Supreme Court vacated forfeiture; suit filed within one year. | County: suit barred by statute of limitations. | County waived the argument on appeal by failing to designate it as an issue; trial court’s timeliness ruling not disturbed. |
| Bad-faith standard under Tenn. Code Ann. § 40-33-215(d) | Sprunger: Haynes’ failure to follow clear statutory forfeiture procedures means the seizure had no reasonable legal basis and thus was in bad faith. | County: Haynes relied on DA’s office and grand jury proceedings; no evidence of intentional, dishonest, or willful conduct or lack of reasonable basis. | Held for County: procedural defects do not automatically equal bad faith; statute requires knowing misconduct or demonstrable indifference or no reasonable basis in law/fact. |
| Scope of required proof to show bad faith | Sprunger: procedural noncompliance suffices to show no reasonable basis. | County: analogous bad-faith contexts (insurance, workers’ comp) require misconduct, indifference, or arbitrary action beyond negligence. | Court adopts a standard requiring some degree of knowing misconduct or indifference; mere procedural mistakes insufficient. |
| Damages period under § 40-33-215(c) | Sprunger: damages should run from seizure until Supreme Court vacatur. | County: (trial court) damages, if any, would run from seizure to foreclosure sale. | Court did not reach damages calculation because plaintiff failed to prove bad faith. |
Key Cases Cited
- State v. Sprunger, 458 S.W.3d 482 (Tenn. 2015) (vacating forfeiture for failure to satisfy statutory notice/procedure)
- Watson v. Tenn. Dep’t of Safety, 361 S.W.3d 549 (Tenn. Ct. App. 2011) (forfeiture statutes construed strictly; notice is essential to due process)
- Redd v. Tenn. Dep’t of Safety, 895 S.W.2d 332 (Tenn. 1995) (adequate notice is essential in forfeiture proceedings)
- Johnson v. Tenn. Farmers Mut. Ins. Co., 205 S.W.3d 365 (Tenn. 2006) (explaining bad-faith standard in insurance context requires disregard or demonstrable indifference)
- Hale v. Commercial Union Assurance Cos., 637 S.W.2d 865 (Tenn. 1982) (bad faith in workers’ compensation/insurance analogies involves fraud or wrongfulness)