Michael Angelo Coleman v. Tennessee Board of Parole, M2016-00410-COA-R3-CV

Background

Michael Angelo Coleman, serving life for murder, was denied parole after hearings in 2011 and 2015; he filed a chancery petition challenging the parole decision and procedures.
Coleman pleaded six counts: Counts I–V sought declaratory and injunctive relief for various constitutional and §1983 claims; Count VI sought review of the Board’s parole denial via the common-law writ of certiorari, alleging arbitrariness and constitutional violations.
The Attorney General moved to dismiss Counts I–V and to dismiss TDOC Commissioner Schofield (not a decisionmaker) from the suit, arguing original actions cannot be joined with a certiorari appellate action.
The trial court granted the partial motion, dismissing Counts I–V with prejudice and removing Commissioner Schofield, concluding certiorari was Coleman’s sole cognizable remedy; the court certified that partial dismissal as final under Tenn. R. Civ. P. 54.02.
Coleman appealed. The Court of Appeals held it lacked subject-matter jurisdiction because the trial court improvidently certified the partial dismissal under Rule 54.02 (and also noted Rule 58 defects), and therefore dismissed the appeal and remanded.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Whether Counts I–V could remain joined with a certiorari action	Coleman: constitutional and civil-rights claims arise from the same transaction and may be joined to avoid duplicative/inconsistent litigation	Respondents: original claims (declaratory, §1983) cannot be joined with an appellate certiorari action; certiorari affords adequate review	Held: Counts I–V and certiorari arise from the same aggregate facts and constitute a single claim for Rule 54.02 purposes; trial court erred to certify partial dismissal as final
2) Whether certiorari is the prisoner’s sole remedy for parole-review constitutional claims	Coleman: certiorari may not cover joint-agency or some declaratory relief; he sought broader relief against multiple actors	Respondents: writ of certiorari provides sufficient review for any constitutional challenge to parole procedures/decision	Held: Court did not decide merits of certiorari scope; focused on procedural jurisdiction—claims overlap and should not be piecemealed on appeal
3) Whether dismissal of Commissioner Schofield and Counts I–V satisfied Rule 54.02 for immediate appeal	Coleman: trial court properly adjudicated claims/party and certified no just reason for delay	Respondents: certification proper because a party was dismissed and legal issues were resolved	Held: Although a party was dismissed, the trial court failed to analyze Rule 54.02 factors; certification was improvident and an abuse of discretion
4) Whether the appellate court had jurisdiction to hear the appeal now	Coleman: timely appealed the partial dismissal certified as final	Respondents: certification was valid so appeal should proceed	Held: Appellate court lacks subject-matter jurisdiction because the partial order was not properly final under Rule 54.02 (and also failed Rule 58 formalities); appeal dismissed

Key Cases Cited

Town of Collierville v. Norfolk S. Ry. Co., 1 S.W.3d 68 (Tenn. Ct. App. 1998) (Rule 3 final-judgment requirement and appealability principles)
Bayberry Assocs. v. Jones, 783 S.W.2d 553 (Tenn. 1990) (Rule 54.02 requires order to be dispositive of an entire claim or party)
Liberty Mut. Ins. Co. v. Wetzel, 424 U.S. 737 (U.S. 1976) (a complaint asserting one legal right, even if seeking multiple remedies, states a single claim for relief)
Ingram v. Wasson, 379 S.W.3d 227 (Tenn. Ct. App. 2011) (Rule 54.02 certification prerequisites and review standards)
Mann v. Alpha Tau Omega Fraternity, 380 S.W.3d 42 (Tenn. 2012) (trial court may convert interlocutory rulings into appealable orders but authority is not absolute)
Johnson v. Nunis, 383 S.W.3d 122 (Tenn. Ct. App. 2012) (Rule 54.02 is an exception allowing trial courts to certify partial final judgments)
Harris v. Chern, 33 S.W.3d 741 (Tenn. 2000) (piecemeal appellate review is disfavored; courts should not routinely certify interlocutory orders under Rule 54.02)
Allis-Chalmers Corp. v. Philadelphia Elec. Co., 521 F.2d 360 (3d Cir. 1975) (factors to weigh when deciding Rule 54(b) certification)