693 S.W.3d 284
Tenn.2024Background
- Plaintiffs alleged that defendants fraudulently obtained rights of redemption to properties sold at tax sales, using forged documents and false representations, and profited from those redemptions.
- Four properties were at issue, involving separate plaintiffs who were heirs or otherwise connected to the properties allegedly taken through fraudulent redemptions.
- After a jury trial largely favorable to defendants (except one fraud claim), plaintiffs moved for a new trial, arguing the trial court failed to fulfill its "thirteenth juror" duty.
- The trial court denied the motion, the Court of Appeals reversed (granting a new trial), and the dispute reached the Supreme Court of Tennessee on further appeal.
- Key dismissed claims included unjust enrichment (based on lack of voluntary conferral of benefit) and misappropriation of redemption rights (conversion of intangible property), both upheld on appeal but reviewed in this Supreme Court decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Remedy when trial judge misconceives "thirteenth juror" duty | New trial is only remedy when court fails in this role | Remand to trial court to fulfill role should be allowed | Remand for the trial court to attempt to fulfill its "thirteenth juror" role is allowed |
| Unjust enrichment claim – voluntary benefit | Did not require voluntary conferral of benefit for recovery | Must be a voluntarily conferred benefit | Voluntary conferral is not required; overruling prior contrary dicta |
| Misappropriation/conversion of right of redemption | Should recognize a claim for conversion of this right | Right of redemption is intangible; no claim | No claim for conversion/misappropriation of intangible right of redemption in Tennessee |
| Proper standard for unjust enrichment test | The correct test is from Freeman Industries (3 elements) | Quantum meruit's 5-element test applies | Three-element test for unjust enrichment is correct; quantum meruit test is not required |
Key Cases Cited
- Holden v. Rannick, 682 S.W.2d 903 (Tenn. 1984) (establishes trial judge’s mandatory duty to act as thirteenth juror)
- Meals ex rel. Meals v. Ford Motor Co., 417 S.W.3d 444 (Tenn. 2013) (affirming thirteenth juror standard and necessity for verdict approval)
- Freeman Indus., LLC v. Eastman Chem. Co., 172 S.W.3d 512 (Tenn. 2005) (sets three-element test for unjust enrichment)
- Whitehaven Cmty. Baptist Church v. Holloway, 973 S.W.2d 592 (Tenn. 1998) (explains unjust enrichment as quasi-contractual remedy)
- Paschall's Inc. v. Dozier, 407 S.W.2d 150 (Tenn. 1966) (emphasizes unjust nature of defendant's benefit as key to unjust enrichment)
- PNC Multifamily Cap. Institutional Fund XXVI Ltd. P’ship v. Bluff City Cmty. Dev. Corp., 387 S.W.3d 525 (Tenn. Ct. App. 2012) (conversion applies only to tangible property)