CHARLES MCCLELLAN CAMPBELL v. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.)
E2025-00430-COA-T10B-CV
Tenn. Ct. App.Apr 14, 2025Background
- This case involves a dispute over the interpretation of a life insurance provision within a permanent parenting plan developed during a prior divorce between Amy Blackwell (now Campbell) and Douglas Blackwell.
- Doug Blackwell's adult children (Plaintiffs) sued Christina Lemek Blackwell (Defendant and widow) to obtain life insurance proceeds received after Doug's death.
- Christina Blackwell sought recusal of Chancellor Jerri S. Bryant, arguing the judge's familiarity with involved attorneys and parties could raise questions of impartiality.
- The trial court denied the recusal motion, finding that general familiarity with local attorneys or parties, even if they may testify, was insufficient to require the judge's recusal.
- Christina Blackwell appealed this denial via an interlocutory appeal as of right under Tenn. Sup. Ct. Rule 10B.
Issues
| Issue | Plaintiff's Argument | Blackwell's Argument | Held |
|---|---|---|---|
| Whether Judge Bryant's familiarity with parties/attorneys requires recusal | Familiarity creates appearance of bias threatening judicial neutrality | Familiarity alone is insufficient; no specific bias or extrajudicial influence shown | Mere familiarity does not mandate recusal; affirmed denial |
Key Cases Cited
- Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (appearance of bias can be as damaging as actual bias; recusal required where impartiality reasonably questioned)
- Kinard v. Kinard, 986 S.W.2d 220 (Tenn. Ct. App. 1998) (judge must be, and be perceived to be, impartial)
- Camp v. Camp, 361 S.W.3d 539 (Tenn. Ct. App. 2011) (familiarity in rural practice does not alone warrant recusal)