Larry Sneed, former Chief of Police for Red Bank, Tennessee, filed a lawsuit against the city following his discharge, alleging wrongful termination under the Tennessee Public Protection Act (TPPA) and age discrimination under the Tennessee Human Rights Act (THRA). He requested a jury trial for both claims. The City of Red Bank sought to transfer the case to circuit court and to have it tried without a jury, citing the Tennessee Governmental Tort Liability Act (GTLA). The trial court granted the transfer and allowed the TPPA claim to proceed without a jury, but permitted a jury trial for the THRA claim, referencing prior case law.
On appeal, the court addressed whether the GTLA applies to THRA claims against municipalities. It reversed the trial court's decision, concluding that the GTLA does apply to THRA claims, thus requiring that claim to also be tried without a jury. The case was remanded for further proceedings in line with this determination. The appellate court’s decision highlighted the legal interpretations of the GTLA in relation to claims against municipalities under the THRA.
In 1973, the General Assembly enacted the Governmental Tort Liability Act (GTLA), establishing that governmental entities generally enjoy immunity from lawsuits for injuries arising from their activities, as codified in Tenn. Code Ann. 29-20-201(a). However, the GTLA specifies limited exceptions to this immunity, including:
1) Negligent operation of motor vehicles or equipment by employees within the scope of their employment.
2) Injuries due to defective or unsafe conditions of streets, alleys, sidewalks, or highways controlled by the entity.
3) Injuries from dangerous or defective conditions of public buildings or structures owned by the entity.
4) Injuries resulting from negligent acts or omissions of employees, barring certain conditions.
The GTLA grants circuit courts exclusive original jurisdiction over claims under the act without jury intervention. Additional legislative acts, such as the Tennessee Human Rights Act (THRA), which applies to both governmental and private employers, further modify governmental immunity. The THRA protects employees from discrimination based on various characteristics and allows claims to be filed with the Tennessee Human Rights Commission or relevant courts. Unlike the GTLA, the THRA does not explicitly address the right to a jury trial.
The current legal question concerns whether THRA claims against municipalities are constrained by the GTLA. Mr. Sneed contends that THRA claims should not be limited by the GTLA, referencing the case Farrow, where the court permitted a jury trial despite the GTLA's stipulations for non-jury trials. However, the relationship between the GTLA and THRA was not explicitly resolved in Farrow. Red Bank argues for a reversal of the trial court's decision, citing the Supreme Court's ruling in Cunningham, which examined the interaction between the GTLA and the Tennessee Medical Malpractice Act, specifically regarding the timeliness of claims against governmental entities.
The Court reviewed the relationship between the Governmental Tort Liability Act (GTLA) and general statutes before directing the dismissal of the complaint. It clarified that statutes of general application conflicting with the GTLA are not applicable unless explicitly stated by the General Assembly, while non-conflicting statutes are upheld. In the case of Cunningham, the Court determined that the statute of limitations in the Tennessee Medical Malpractice Act (TMMA) was inconsistent with that of the GTLA and required clear legislative intent to apply to GTLA cases. It noted that the TMMA was amended in 2011 to redefine ‘health care liability action’ to include claims against the state or political subdivisions, but this amendment was not at issue in the current case.
Mr. Sneed's claims were filed under the Tennessee Human Rights Act (THRA) and the Tennessee Public Protection Act (TPPA), which he argued should not be governed by the GTLA. The Court compared his situation to Young, where it was determined that TPPA claims must be tried in circuit court under the GTLA. The Court emphasized that the distinction between claims against governmental entities and private citizens is crucial, particularly regarding sovereign immunity. The GTLA allows private rights of action against governmental entities while removing common law sovereign immunity, necessitating compliance with its provisions for such suits.
The GTLA mandates that suits against governmental entities be tried in circuit court without a jury, while the THRA allows for either chancery or circuit court without specifying jury intervention. In the absence of an explicit provision, the Court held that the GTLA applies to THRA claims against municipalities, requiring trial in circuit court without a jury. Consequently, the trial court's judgment was reversed, and the case was remanded for further proceedings in line with this opinion, with costs imposed on the appellee, Larry Sneed. The Court acknowledged a conflicting district court order but noted it was not binding.
