Southern Constructors, Inc. v. Loudon County Board of Education

Summary

The Tennessee Supreme Court held that a county board of education possesses authority to arbitrate disputes arising out of a school construction contract because that power is fairly implied from the board's express statutory power to enter into construction contracts, even though no statute expressly mentions arbitration. The Court declined invitations to abrogate Dillon's Rule, retaining strict-but-reasonable construction of delegated local governmental authority while recognizing exceptions for expressed legislative intent favoring broad construction, comprehensive general grants, general welfare powers, and home rule municipalities. Applying that framework, the Court concluded the Loudon County Board's arbitration agreement and the resulting award were not ultra vires, that the Board was entitled to summary judgment, and it reversed the Court of Appeals and dismissed Southern Constructors' suit challenging the award.