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Pam Lowery and Debbie Nelson v. Robert McVey

Citation: Not availableDocket: M2012-00555-COA-R3-CV

Court: Court of Appeals of Tennessee; February 10, 2013; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, a dispute arose over a parcel of land co-owned by McVey and his deceased brother's children, who sought partition due to disputes over debris and personal property. Following a series of court orders mandating McVey to remove his belongings, he was found in contempt for noncompliance. Despite the court's order to clear personal property, McVey dismantled and removed structures on the property, prompting a second contempt petition. The trial court found McVey in contempt for failing to remove specific items but determined that the destruction of structures did not breach its prior order, hence no damages were awarded. The Sisters appealed the decision, arguing the court erred in not awarding damages for McVey's actions. The appellate court reviewed the matter under an 'abuse of discretion' standard and affirmed the trial court's rulings, upholding the decision to deny damages and awarding attorney fees to the Sisters. The court emphasized the need for orders to be clear and specific, noting that McVey's actions, while unauthorized, were not explicitly forbidden by the court's prior order.

Legal Issues Addressed

Applicability of T.C.A. 29-9-105 for Damages

Application: The trial court concluded that damages under T.C.A. 29-9-105 were not warranted as McVey’s removal of structures was not expressly prohibited by the prior order.

Reasoning: The trial court evaluated the Sisters' request for damages related to fixtures and structures removed or damaged by McVey...deeming the removal lawful.

Civil Contempt and Court Orders

Application: The court ruled that McVey's actions did not constitute contempt regarding the removal of structures, as the original order did not clearly prohibit such actions.

Reasoning: The court found that McVey's subsequent actions—damaging and removing buildings and structures—were not authorized by this order.

Contempt of Court under Tennessee Law

Application: The trial court found McVey in contempt for failing to comply with the order to remove personal property and livestock, but it did not award damages for the destruction of structures.

Reasoning: The trial court found McVey in willful contempt for failing to remove his possessions and livestock, having instead added a renter.

Standard of Review for Contempt Sanctions

Application: The appellate court applied the 'abuse of discretion' standard, affirming the trial court's decision not to award damages for contempt.

Reasoning: The appellate court affirmed the trial court's findings, concluding there was no abuse of discretion in the sanctions imposed on McVey.