Self v. Simmons, 1:24-cv-00267

This action arises from a fatal automobile accident in McMinn County, Tennessee in August 2023, where defendant Simmons, allegedly intoxicated and speeding in a TVA vehicle, struck and killed Joseph Self.
Plaintiff, Rick Self (as next of kin), sues Simmons for wrongful death and TVA for respondeat superior, negligent entrustment, and negligent training/supervision.
Simmons faces concurrent criminal charges (vehicular homicide, vehicular assault, reckless driving), with a possible plea agreement and a hearing set for April 2025.
Simmons seeks to stay the civil case against him to protect his Fifth Amendment rights during pending criminal proceedings.
Plaintiff opposes a broad stay; TVA joins Simmons' motion and requests, if any stay is granted, that the entire case be stayed—not just claims against Simmons.
The court must decide whether to stay the case, balancing parties’ and judicial interests, and considering potential prejudice and inefficiency from partial discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the civil case (or part thereof) should be stayed pending Simmons' criminal case	Opposes full stay; seeks limited discovery and case-by-case protection for Simmons’s Fifth Amendment rights	Stay is necessary to protect Simmons’ rights; continued litigation risks prejudice and inefficiency; TVA requests a full stay for efficiency	Court grants full stay for all parties pending resolution of Simmons's criminal proceedings

Fed. Trade Comm’n v. E.M.A. Nationwide, Inc., 767 F.3d 611 (6th Cir. 2014) (outlines the standard for granting stays in civil proceedings pending related criminal cases)
Chao v. Fleming, 498 F. Supp. 2d 1034 (W.D. Mich. 2007) (lists relevant factors for considering a stay and emphasizes overlap between civil and criminal actions)
Trs. of Plumbers & Pipefitters Nat’l Pension Fund v. Transworld Mech., Inc., 886 F. Supp. 1134 (S.D.N.Y. 1995) (discusses reasons to stay civil proceedings pending criminal resolution)