Kristie Jackson sued Williamson Sons Funeral Home for negligence and negligent infliction of emotional distress after the burial of her mother, Edna Louise Lewis. Jackson claimed the Funeral Home acted negligently by proceeding with the burial despite her objections regarding the burial location, which she asserted was against her mother’s wishes. After the Funeral Home moved for summary judgment, the trial court granted the motion, determining that the Funeral Home did not owe Jackson a duty to delay the burial as she requested. The court concluded that Jackson failed to demonstrate a necessary element of her claim, specifically the existence of a duty owed by the Funeral Home. Jackson appealed, and the appellate court affirmed the trial court’s decision, concluding that there was no error in granting summary judgment based on the lack of duty. Jackson sought $75,000 in damages for emotional distress and costs associated with moving her mother’s remains. The appellate court’s judgment upheld the lower court's dismissal of the complaint.
Summary judgment is warranted when there is no genuine issue of material fact relevant to the claim, and the moving party is entitled to judgment as a matter of law. A motion for summary judgment must either negate an essential element of the nonmoving party’s claim or demonstrate that the nonmoving party cannot prove an essential element at trial. Once properly supported, the burden shifts to the nonmoving party to show a genuine issue of material fact, requiring proof through affidavits or discovery materials rather than relying solely on pleadings. If the nonmoving party fails to respond adequately, summary judgment may be granted. On appeal, courts review summary judgment de novo, considering all evidence in favor of the nonmoving party. Summary judgment will be upheld if undisputed facts lead to only one conclusion.
In the discussion involving Ms. Jackson and the Funeral Home, Ms. Jackson claims that the Funeral Home breached a duty of care by proceeding with funeral arrangements despite the objection of a person with authority over the body. The Funeral Home argues it owed no duty to Ms. Jackson due to a lack of relationship and contends the duty she seeks to impose is unreasonable. To succeed in a negligence claim in Tennessee, a plaintiff must establish the existence of a duty of care, a breach of that duty, resulting injury, and causation. For claims of negligent infliction of emotional distress, expert proof of severe emotional distress is also necessary. In both cases, the existence of a legal duty is the threshold requirement; without it, there can be no breach of duty.
Duty in negligence cases is specific to the plaintiff-defendant relationship, as established in Nichols v. Atnip. Determining whether a defendant owed a duty is a legal question, while assessing a breach of that duty is factual. The trial court's summary judgment was valid if the Funeral Home had no legal duty to Ms. Jackson. The existence of a duty hinges on whether a relationship necessitates a legal obligation for one party to protect the interests of another, as clarified in Coln v. City of Savannah. Duty is defined as the obligation to adhere to a reasonable person standard to mitigate unreasonable risks of harm, wherein a risk is deemed unreasonable if the potential harm outweighs the burden of alternative conduct to prevent it.
Assuming a duty exists, it must be evaluated whether the defendant met the appropriate standard of care, which is always reasonable care relative to the apparent risk. Ms. Jackson referenced Steinbrunner v. Turner Funeral Home to assert that the Funeral Home owed her a duty based on her relationship to the deceased. However, unlike in Steinbrunner, she was not the contracting party with the Funeral Home. Ms. Jackson's claim that her authority as next of kin created a similar duty was rejected; the court deemed that imposing such a duty was unwarranted under the circumstances. Since Ms. Lewis had no surviving spouse, her adult children, including Ms. Jackson, possessed the authority to determine the burial, granting them standing to sue for negligent handling of the body, as supported by precedent in Crawford v. J. Avery Bryan Funeral Home and Akers v. Buckner-Rush Enterprises.
The Funeral Home is not required to mediate family disputes or delay burials due to disagreements from relatives who did not participate in contracting for services. The legal context differs significantly from prior cases (Steinbrunner, Crawford, and Akers), where the duties involved were not applicable here. The existence and nature of any duty owed depend on the relationship between the parties involved, which in this case does not support a duty to Ms. Jackson. Imposing such a duty would create an impractical burden on the Funeral Home, as it would need to coordinate with multiple family members who may have rights over the body’s disposition. While the Funeral Home is responsible for appropriately handling and burying the body, it is not obligated to ensure consensus among all relatives regarding arrangements. Ms. Jackson failed to establish that a duty existed under these circumstances, leading to no genuine issues of material fact. The trial court's decision to grant summary judgment is upheld, and the case is remanded for any necessary further proceedings, with appeal costs assigned to Ms. Jackson.
