Timothy O'Guin v. State of Tennessee, M2020-00732-COA-R3-CV

Joseph O’Guin, admitted to the Tennessee State Veterans’ Home after a stroke, was wheelchair-bound with left-sided hemiparesis.
Two days after admission he rolled his wheelchair off the edge of the front sidewalk, suffered serious injuries, and died five days later.
The estate administrator sued the State in the Tennessee Claims Commission for negligent creation/maintenance of a dangerous condition on state property (alleging inadequate markings/barriers at the sidewalk/curb).
Plaintiff relied on two facility accident reports and testimony from the facility administrator confirming a wheelchair wheel went over the sidewalk edge; photographs showed an ordinary paved sidewalk.
The State moved for summary judgment limited to causation; the Claims Commission granted summary judgment for the State, finding plaintiff’s evidence insufficient to prove the State’s conduct more likely than not caused the fall.
On appeal the Court of Appeals affirmed, holding plaintiff failed to exclude other possible causes (e.g., distraction, sun, patient’s condition) or show the sidewalk’s condition was the probable cause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff proved causation in fact for negligence claim	Accident reports and administrator testimony show wheelchair wheels left sidewalk due to curb/sidewalk condition; prior wheelchair accidents put State on notice	Evidence only shows wheels left the sidewalk; no proof the sidewalk/curb condition more likely than not caused the fall; other causes possible	Held for State — plaintiff’s evidence insufficient to show cause-in-fact (must be "more likely than not")
Whether Claims Commission exceeded scope of State’s summary-judgment motion	Commission allegedly relied on other grounds beyond causation	Even if scope issue exists, summary judgment proper on causation alone	Court declined to address scope claim because causation disposal was dispositive

Byrd v. Hall, 847 S.W.2d 208 (Tenn. 1993) (summary judgment burden and appellate review standards)
Rye v. Women’s Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235 (Tenn. 2015) (movant may show nonmovant’s evidence is insufficient on an essential element)
Lindsey v. Miami Dev. Corp., 689 S.W.2d 856 (Tenn. 1985) (plaintiff must prove defendant’s conduct was a cause in fact — more likely than not)
Jenkins v. Big City Remodeling, 515 S.W.3d 843 (Tenn. 2017) (circumstantial evidence of causation must tend to exclude other causes)
Doe v. Linder Constr. Co., 845 S.W.2d 173 (Tenn. 1992) (proof of negligence without proof of causation is insufficient)
Kilpatrick v. Bryant, 868 S.W.2d 594 (Tenn. 1993) (but-for causation requirement)
Hames v. State, 808 S.W.2d 41 (Tenn. 1991) (Claims Commission Act waiver of sovereign immunity for premises liability)