Michael Goodrum v. State of Tennessee
M2016-00684-CCA-R3-PC
| Tenn. Crim. App. | Jul 25, 2017Background
- Terry Vaughn, an inmate at Coffee County Jail, was injured when a gravestone fell and crushed his leg while he worked on a City of Tullahoma–supervised cemetery detail.
- Vaughn sued the City and Coffee County under the Tennessee Governmental Tort Liability Act (GTLA) for negligence.
- Defendants moved for summary judgment asserting Tenn. Code Ann. § 41-2-123(d)(2) bars recovery by prisoners on work details except for medical treatment paid during confinement.
- The County submitted an affidavit showing it paid $10,053.56 in Vaughn’s medical bills during incarceration; the City reimbursed the County $5,686.50. Vaughn did not dispute that medical expenses incurred during confinement were paid.
- The trial court granted summary judgment for the City and County, holding § 41-2-123(d)(2) controls and limits recovery to medical expenses already paid. Vaughn appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GTLA or Tenn. Code Ann. § 41-2-123(d)(2) governs an inmate injured on a work detail | Vaughn: GTLA governs; its waiver of immunity applies and allows recovery under §§ 29-20-204/205 | City/County: § 41-2-123(d)(2) is the specific statute for inmate work-detail injuries and limits recovery to paid medical treatment | Court: § 41-2-123(d)(2) is a specific exception to the GTLA and controls; GTLA does not provide additional recovery here |
| Whether unpaid damages remain after defendants paid medical expenses during confinement | Vaughn: factual disputes about negligence preclude summary judgment and he could recover beyond medical costs under GTLA | Defendants: § 41-2-123(d)(2) limits liability to medical treatment during confinement, which has been paid, so no further recovery | Court: Medical expenses during confinement were paid and undisputed; thus no additional recovery available and summary judgment appropriate |
Key Cases Cited
- City of Lavergne v. S. Silver, Inc., 872 S.W.2d 687 (Tenn. Ct. App.) (discussing municipal immunity and GTLA context)
- Wilson v. Johnson County, 879 S.W.2d 807 (Tenn.) (rules for statutory construction and legislative intent)
- Koella v. State ex rel. Moffett, 405 S.W.2d 184 (Tenn.) (special statutory provision as exception to general statute)
- Rye v. Women’s Care Center of Memphis, MPLLC, 477 S.W.3d 235 (Tenn.) (standard of review for summary judgment)
- Belle–Aire Village, Inc. v. Ghorley, 574 S.W.2d 723 (Tenn.) (construction of statutes in pari materia)