Joe Mosley v. State of Tennessee
475 S.W.3d 767
| Tenn. Ct. App. | 2015Background
- Mosley, a former TDOC inmate, alleges he served 697 days beyond his ten-year sentence due to miscalculation of sentence credits.
- He filed a Division of Claims Administration claim May 29, 2013; the claim was transferred to the Tennessee Claims Commission after the 90-day window.
- Mosley filed a Complaint for Damages February 12, 2014, alleging negligent care, custody, and control and statutory-credit calculation failures.
- The State moved to dismiss March 13, 2014, arguing lack of subject-matter jurisdiction and absence of a private right of action.
- The Claims Commission dismissed June 9, 2014 for lack of jurisdiction, holding the gravamen was negligent deprivation of statutory rights with no private right of action; Mosley appealed.
- The Tennessee Court of Appeals affirmed, concluding the claim is within 9-8-307(a)(1)(N) and lacks a private right of action, and that Mosley failed to exhaust declaratory remedies; it also found Mosley could not amend without court leave after a motion to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Claims Commission had jurisdiction over Mosley’s claim. | Mosley contends the claim fits within negligent care, custody, and control. | State argues claim falls under negligent deprivation of statutory rights (a(N)) requiring a private right of action; no such right exists here. | Yes; no subject-matter jurisdiction because no private right of action exists under 9-8-307(a)(1)(N). |
| Whether Mosley could amend his complaint after a motion to dismiss. | Mosley sought to amend to clarify reliance on negligent failure to release. | Amendment allowed only with leave when a responsive pleading is filed; here it was not. | Yes; Court affirmed that Mosley was entitled to amend without court leave, but no reversible error occurred. |
Key Cases Cited
- Stewart v. State, 33 S.W.3d 785 (Tenn. 2000) (jurisdiction over negligent control of a person by a state employee)
- Mullins v. State, 320 S.W.3d 273 (Tenn. 2010) (Claims Commission exclusive jurisdiction; liberal construction but no extension beyond statute)
- Beare Co. v. Olsen, 711 S.W.2d 603 (Tenn. 1986) (sovereign immunity waivers must be strictly construed)
- Conley v. State, 141 S.W.3d 591 (Tenn. 2004) (jurisdictional framework for monetary claims against the State)
- Brown v. Brown, 281 S.W.2d 492 (Tenn. 1955) (sovereign immunity and waiver principles)