planning-operational test (Tennessee) · Go Syfert
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planning-operational test in Tennessee

31 Tennessee opinions name it 2 courts 1992–2022 1 in the last five years

The cases below were cited by Tennessee courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Carlson v. Stategreen
alaska · 1979 · cited in 11 Tennessee opinions naming this issue, 1992–2018
2 sentences

2018See Carlson v. State, 598 P.2d 969, 972 (Alaska 1979).

2006In Bowers , the Supreme Court adopted the planning-operational test, explaining that “[u]nder the planning-operational test, decisions that rise to the level of planning or policy-making are considered discretionary acts which do not give rise to tort liability, while decisions that are merely operational are not considered discretionary acts and, therefore, do not give rise to immunity.” Bowers, 826 S.W.2d at 430 (citing Carlson v. State, 598 P.2d 969, 972 (Alaska 1979)).

1111
Bowers by Bowers v. City of Chattanoogagreen
tenn · 1992 · cited in 24 Tennessee opinions naming this issue, 1992–2022
2 sentences

2018However, the Tennessee Supreme Court articulated the test for determining whether an act is discretionary in Bowers by Bowers v. City of Chattanooga, 826 S.W.2d 427 (Tenn. 1992), to-wit: Under the planning-operational test, decisions that rise to the level of planning or policy-making are considered discretionary acts which do not give rise to tort liability, while decisions that are merely operational are not considered discretionary acts and, therefore, do not give rise to immunity.

2016The TGTLA does not define the term “discretionary function,” but our Supreme Court, in Bowers v. City of Chattanooga, 826 S.W.2d 427 (Tenn. 1992), adopted the planning-operational test to assist courts in analyzing whether the negligent act or omission of the governmental entity at issue in the case is a discretionary function.

924
United States v. Gaubertgreen
scotus · 1991 · cited in 4 Tennessee opinions naming this issue, 1997–2004
2 sentences

1997See United States v. Gaubert, 499 U.S. ___ , 111 S.Ct. 1267 , 113 L.Ed.2d 335 (1991) (recognizing that operational activities grounded in policy are entitled to discretionary function immunity.) Under the planning-operational test, discretionary function immunity does not automatically attach to all acts involving choice or judgment.

1997See United States v. Gaubert, 499 U.S. ___ , 111 S.Ct. 1267 , 113 L.Ed.2d 335 (1991) (recognizing that operational activities grounded in policy are entitled to discretionary function immunity.) Under the planning-operational test, discretionary function immunity does not automatically attach to all acts involving choice or judgment.

44
Helton v. Knox County, Tenn.green
tenn · 1996 · cited in 1 Tennessee opinions naming this issue, 2012–2012
1 sentence

2012A governmental entity is immune from suit for actions involving “planning or policy-making.” Helton v. Knox Cnty., 922 S.W.2d 877, 885 (Tenn. 1996) (quoting Bowers, 826 S.W.2d at 430 ).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Limbaugh v. Coffee Medical Center green
tenn · 2001
2 sentences

2012Bowers, 826 S.W.2d at 430 . *** Our Supreme Court applied the planning-operational test in Limbaugh v. Coffee Medical Center, 59 S.W.3d 73 (Tenn. 2001), to determine whether a nursing home’s failure to follow employee disciplinary guidelines was a discretionary function for which immunity was available under the TGTLA.

2011Our Supreme Court applied the planning-operational test in Limbaugh v. Coffee Medical Center, 59 S.W.3d 73 (Tenn.2001), to determine whether a nursing home’s failure to follow employee disciplinary guidelines was a discretionary function for which immunity was available under the TGTLA.

32002–2012
Cox v. State green
tennctapp · 1992
2 sentences

2004Id. at * 3; Cox v. State, 844 S.W.2d at 176 .

2004Id. at *3; Cox v. State, 844 S.W.2d at 176 .

32002–2004
GIGGERS v. Memphis Housing Authority green
tenn · 2012
1 sentence

2012In Giggers v. Memphis Housing Authority, 363 S.W.3d 500 (2012), the Tennessee Supreme Court recently reviewed the planning-operational test: To determine whether a governmental entity is entitled to immunity for a discretionary decision, this Court applies the “planning-operational test.” Bowers v. City of Chattanooga, 826 S.W.2d 427, 430 (Tenn. 1992).

12012–2012
Carter v. City of Stuart green
fla · 1985
1 sentence

1997Id. at 957 .

11997–1997

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 29-20-205 (30) TN § Tenn. Code Ann. § 29-20-201 (16) TN § Tenn. Code Ann. § 29-20-101 (10) TN § Tenn. Code Ann. § 29-20-203 (6) TN § Tenn. Code Ann. § 29-20-204 (3) TN § Tenn. Code Ann. § 29-20-307 (3) TN § Tenn. Code Ann. § 8-42-101 (3) TN § Tenn. Code Ann. § 9-8-307 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TN 31 (1992–2022) AK 9 (1974–2019) IN 7 (1993–2020) ID 3 (1983–1987)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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