Debbie Williams v. Rodney Holt
M2024-01188-COA-R3-CV
Tenn. Ct. App.May 1, 2025Background
- Plaintiff Debbie Williams was left by a transit bus driver, Rodney Holt, at a bus stop after he closed the door and drove away, despite her request for assistance boarding.
- The incident occurred on November 15, 2022, and after being left, Williams had to wait about 26 minutes in cold weather for the next bus.
- Williams reported the incident to Tyquenta Keys, a customer service employee, who said she would file a complaint but did not do so, though Williams herself did file complaints.
- The Metropolitan Transit Authority (MTA) and its contractor did not retain the bus video footage since it was automatically overwritten.
- Williams filed a lawsuit, pro se, alleging intentional infliction of emotional distress (IIED) against Holt and Keys, and negligent infliction of emotional distress (NIED) against MTA as their supposed employer.
- The trial court granted summary judgment to all defendants, finding no extreme or outrageous conduct and that MTA was not the employer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of Motion to Compel Discovery | Needed more discovery to support her claims; denial was improper | Discovery unnecessary as facts not in dispute for summary judgment | Denial affirmed; no abuse of discretion |
| Sufficiency of Grant of Summary Judgment Order | Trial court’s order did not sufficiently state legal grounds | Order provided legal reasoning and findings | Order complied with Rule 56.04 |
| IIED Claim Against Holt and Keys | Conduct was extreme and caused severe distress | Conduct was not extreme or outrageous | Conduct not extreme/out-rageous; summary judgment for defendants |
| NIED Claim Against MTA | MTA was responsible as employer for employees’ actions | Holt/Keys employed by DTO, not MTA; insufficient duty evidence | MTA had no duty; summary judgment affirmed |
Key Cases Cited
- Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (sets forth elements and high threshold for IIED claims)
- Eskin v. Bartee, 262 S.W.3d 727 (Tenn. 2008) (outlines serious or severe proof requirement for NIED)
- Miller v. Willbanks, 8 S.W.3d 607 (Tenn. 1999) (emphasizes the “exacting standard” for IIED recovery)
- McClung v. Delta Square Ltd., P’ship, 937 S.W.2d 891 (Tenn. 1996) (recites negligence elements)
- Hale v. Ostrow, 166 S.W.3d 713 (Tenn. 2005) (clarifies duty as threshold element in negligence)