Jan Byrd, Plaintiff-Appellant v. Dr. Thomas K. Hall, Dr. Maxwell E. Huff, and Dr. David Bruce Coffey…

Summary

The Tennessee Supreme Court granted review to settle the proper standard for evaluating summary judgment motions under Tenn. R. Civ. P. 56. The court reaffirmed existing Tennessee principles and embraced the federal 1986 trilogy construction of the virtually identical federal rule, articulating a three-part inquiry — whether a factual dispute exists, whether the disputed fact is material under the substantive law, and whether it creates a genuine issue a reasonable jury could resolve — and confirming that the movant bears the burden while the nonmoving party must produce specific, trial-admissible facts and may not rest on pleadings. Applying that framework, the court held the plaintiff's opposing affidavit raised genuine issues of material fact on his tortious-interference-with-employment claim where the defendant physicians denied the events occurred and submitted no countervailing affidavits, and it reversed and remanded for trial.