Tina Yvette Vaughn v. Methodist Hospital Staff & Aministration
W2016-00422-COA-R3-CV
| Tenn. Ct. App. | May 8, 2017Background
- Vaughn (pro se) sued Methodist Healthcare–Memphis Hospitals for defamation after hospital personnel allegedly made statements to police on July 17, 2013.
- Vaughn initially filed a general sessions warrant on July 15, 2014; at the general sessions hearing she testified the statements occurred July 17, 2013.
- General sessions court dismissed the claim as time‑barred under the six‑month slander statute; Vaughn appealed to the Shelby County Circuit Court.
- Methodist moved for summary judgment in circuit court arguing the claim sounded in slander (spoken) and thus was governed by Tenn. Code Ann. § 28‑3‑103 (six months). Vaughn produced no writing by Methodist supporting libel.
- The trial court granted summary judgment, holding Vaughn’s claim was slander, not libel, and was filed more than six months after the July 17, 2013 statements.
- The Court of Appeals affirmed, concluding the claim was time‑barred and remanding; costs assessed to Vaughn.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Characterization: Is the claim libel (written) or slander (spoken)? | Vaughn alleged defamation generally and referenced a newspaper article at the hearing as possible publication. | Methodist argued Vaughn testified the offending statements were spoken to police by staff and no written publication by Methodist existed. | Court: The claim sounded in slander; Vaughn offered no evidence of a Methodist written publication to support libel. |
| Timeliness: Is the claim barred by the statute of limitations? | Vaughn filed suit July 15, 2014 and implied the complaint was timely or sought records to support libel. | Methodist argued slander claims must be filed within six months of the utterance (Tenn. Code Ann. § 28‑3‑103); Vaughn’s suit was after six months. | Court: Slander six‑month limitation applies; suit filed over six months after July 17, 2013 and is time‑barred. |
Key Cases Cited
- Rye v. Women's Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235 (Tenn. 2015) (standard of review for summary judgment)
- Bain v. Wells, 936 S.W.2d 618 (Tenn. 1997) (summary judgment review framework)
- Quality Auto Parts Co., Inc. v. Bluff City Buick Co., Inc., 876 S.W.2d 818 (Tenn. 1994) (distinguishing libel and slander)
- Hodges v. Tenn. Att’y Gen., 43 S.W.3d 918 (Tenn. Ct. App. 2000) (pro se litigants held to same procedural standards)