Ronnie Bradfield v. Steve Dotson

Citation: Not availableDocket: 02A01-9902-CV-00060

Court: Court of Appeals of Tennessee; August 16, 1999; Tennessee; State Appellate Court

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Ronnie Bradfield, an inmate at the Lake County Regional Correctional Facility, filed a defamation lawsuit against state employees Ouida Stamper and Steve Dotson, alleging they maliciously provided false information about him to the Shelby County Criminal Court, which harmed his legal interests. The trial court initially dismissed the case, ruling that the Tennessee Claims Commission had exclusive jurisdiction. Bradfield appealed, and the appellate court found no basis for the dismissal due to lack of subject matter jurisdiction, leading to a remand. Upon remand, the defendants submitted affidavits stating their actions were related to a pre-sentence report for Bradfield's sentencing. The trial court granted summary judgment in favor of the defendants, dismissing the case. On appeal, Bradfield argued that the trial court erred by not awarding him a default judgment and by dismissing his complaint without addressing his discovery requests. The appellate court criticized the trial court for not considering these requests before granting summary judgment.

On February 17, 1998, the court reversed a prior summary judgment by the trial court, remanding the case to allow consideration of Bradfield's motion to compel discovery. Following this, the trial court mandated that defendants respond to discovery requests by April 17, 1998. By November 9, 1998, the trial court confirmed that the defendants had complied, closing discovery and allowing thirty days for additional pleadings. On December 9, 1998, the defendants filed a motion for summary judgment, to which Bradfield responded by January 7, 1999. On February 3, 1999, the trial court granted the defendants' motion, dismissing the lawsuit on grounds of lack of subject matter jurisdiction and determining that the defendants acted within the scope of their employment with the State of Tennessee.

Bradfield appealed on February 22, 1999, and the appeal addressed whether the trial court had jurisdiction over a defamation claim against state employees acting within their employment scope. According to T.C.A. 9-8-307(a)(1)(R. Supp. 1995), exclusive jurisdiction for such claims lies with the commission. In affidavits from Ouida Stamper, a defendant and Probation Manager for the Tennessee Department of Correction (TDOC), she asserted that her involvement in Bradfield's case was solely in her professional capacity. She detailed her actions in preparing a presentence report for the Shelby County Criminal Court, which was conducted per a court order, indicating that all her interactions with Bradfield were within the course of her employment.

Associate Warden Steve Dotson, in his affidavit dated April 23, 1997, denied defaming Mr. Bradfield by asserting he provided false information to the Shelby County Criminal Court. Dotson clarified that, while he did provide information regarding Bradfield’s prison adaptation to the TDOC Probation Manager Ouida Stamper in response to an inquiry, he did not directly communicate with the court. This information was part of a presentence report submitted to the court at its request, and Dotson's actions were within the scope of his employment.

In a subsequent affidavit sworn on December 2, 1998, Dotson reiterated his employment with the Tennessee Department of Correction and his responsibility to supply information for presentence investigations. The affidavits from Dotson and Stamper establish that both acted within their employment scope.

Citing T.C.A. 9-8-307(a)(1)(R, 1992), the Claims Commission has exclusive jurisdiction over libel and slander claims against state employees acting within their employment scope. The trial court's dismissal of Bradfield’s claims was supported by the introduction of unrefuted affidavits demonstrating the defendants' employment status.

Even if the trial court had jurisdiction, Bradfield’s defamation claims would fail for two reasons: first, Stamper's statements were absolutely privileged as they were made in the context of a judicial proceeding, aligning with Tennessee Supreme Court precedents. Second, Dotson’s communications with Stamper did not constitute defamation because they were not published outside the scope of their employment, as established in prior case law.

Consequently, the trial court's dismissal of Bradfield's claims was affirmed, with costs of the appeal taxed to him.