Woods v. Metropolitan Development & Housing Authority Board of Commissioners
345 S.W.3d 903
Tenn. Ct. App.2011Background
- Woods, a long-time MDHA property manager, was terminated in 2008 amid sexual-harassment allegations and concerns about his duties including monthly reporting.
- MDHA employed Woods for 29 years in several properties housing thousands of residents.
- An MDHA investigator found inconsistencies in harassment claims; a hearing officer recommended demotion rather than termination.
- MDHA Board rejected the hearing officer, citing risk of negligent retention liability and Woods’s at-will status.
- Woods filed a common-law writ of certiorari; the trial court found Woods at-will and not arbitrarily treated.
- The appellate court reviews a Board decision under a narrow certiorari standard and ultimately affirms the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the MDHA manual created a contract requiring just cause for termination. | Woods; handbook language binds MDHA. | Manual lacks binding contract language. | The manual did not create a contract; Woods was at-will. |
| Whether the Board's termination was arbitrary or illegal given Woods’s at-will status. | Termination was not for just cause and was capricious. | Board acted within its discretion to terminate to avoid liability and ensure safety. | Board's termination not arbitrary or illegal under certiorari standard. |
| What is the proper scope of review for a writ of certiorari in this context? | Court should reweigh evidence to determine correctness. | Review limited to whether Board acted within jurisdiction and with evidence supporting its decision. | Scope is highly limited; must show arbitrariness, illegality, or lack of jurisdiction; the record supports the Board. |
Key Cases Cited
- Rose v. Tipton County Public Works Dept., 953 S.W.2d 690 (Tenn.Ct.App.1997) (employment at-will presumption; manual may create contract if intended)
- Smith v. Morris, 778 S.W.2d 857 (Tenn.Ct.App.1988) (handbook provisions can form contract if language binding)
- King v. TFE, Inc., 15 S.W.3d 457 (Tenn.Ct.App.1999) (binding terms required for contract interpretation of handbook)
- Claiborne v. Frito-Lay, Inc., 718 F. Supp. 1319 (E.D.Tenn.1989) (manual context in contract interpretation; unilateral board rights conflict with contract?)
- Ussery v. City of Columbia, 316 S.W.3d 570 (Tenn.Ct.App.2009) (handbook without disclaimer may create contract; disclaimer matters)
- MacDougal v. Sears, Roebuck & Co., 624 F. Supp. 756 (E.D.Tenn.1985) (past practices may imply contract; explicit disclaimers important)
- Leonard Plating Co. v. Metropolitan Gov't of Nashville and Davidson County, 213 S.W.3d 898 (Tenn.Ct.App.2006) (scope of review; material evidence supports Board decision)