Verrina M. Shields Bey v. Wilson & Associates, PLLC, W2016-01330-COA-R3-CV

Appellant Verrina M. Shields Bey (pro se) filed a quiet-title and declaratory/injunctive action on May 9, 2016 against Wilson & Associates, PLLC and Wells Fargo regarding 2486 Harvard Avenue, Memphis.
Trial court apparently orally dismissed the complaint (May 10, 2016); no written order was immediately entered. Appellant moved for interlocutory appeal; that motion was denied May 20, 2016.
Appellant filed a notice of appeal June 20, 2016; the Court of Appeals twice ordered her to obtain entry of a final judgment or show cause why the appeal should not be dismissed.
Appellant failed to secure a final order; the trial court entered a written order March 20, 2017, dismissing the complaint sua sponte as barred by res judicata.
The Court of Appeals concluded Appellant’s brief was fatally deficient (rambling, incoherent, lacking required record citations, authorities, statement of facts, standards of review, and precise relief) and dismissed the appeal.
The Court declined Wells Fargo’s request to deem the appeal frivolous or to impose sanctions; costs were taxed to Appellant (in forma pauperis status noted).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether interlocutory appeal denial is reviewable	Shields Bey sought appellate review of the trial court’s interlocutory ruling and later appeal from denial	Appellees maintained that procedural defects and lack of final judgment precluded relief	Appeal dismissed for failure to comply with appellate briefing rules; merits not reached
Whether a final judgment existed to support appeal	Appellant proceeded with appeal despite absence of written final order	Appellees implied the absence of a final order and procedural deficiencies	Court directed entry of final judgment; lack of compliance led to dismissal
Whether appellate brief met Rule 27 and Ct. App. Rule 6 requirements	Appellant’s brief attempted to raise issues but lacked record citations, authorities, standards, and clear arguments	Appellees argued the brief was noncompliant and issues should be waived	Brief held fatally deficient; issues deemed waived and not considered
Whether sanctions for frivolous appeal were warranted	N/A (Appellant did not press sanctions issue)	Wells Fargo requested frivolousness finding and sanctions	Court declined to impose sanctions despite dismissing the appeal

Hodge v. Craig, 382 S.W.3d 325 (Tenn. 2012) (failure to include Rule 27(a)(7) argument may waive issue on appeal)
Forbess v. Forbess, 370 S.W.3d 347 (Tenn. Ct. App. 2011) (failure to cite authority or develop arguments constitutes waiver)
Sneed v. Bd. of Prof'l Responsibility of Supreme Court, 301 S.W.3d 603 (Tenn. 2010) (courts will not construct arguments for parties; skeletal arguments are waived)
Irvin v. City of Clarksville, 767 S.W.2d 649 (Tenn. Ct. App. 1989) (pro se litigants must follow same procedural rules as represented parties)
Whitaker v. Whirlpool Corp., 32 S.W.3d 222 (Tenn. Ct. App. 2000) (pro se litigants bear burden to comply with substantive and procedural requirements)
Bean v. Bean, 40 S.W.3d 52 (Tenn. Ct. App. 2000) (appellate courts may decline to consider cases where rules were not complied with)
Waters v. Farr, 291 S.W.3d 873 (Tenn. 2009) (appellate courts may decline to consider issues not raised and briefed per rules)
Crowe v. Birmingham & N.W. Ry. Co., 1 S.W.2d 781 (Tenn. 1928) (historical authority supporting refusal to consider appeals where procedural noncompliance exists)