wrongful death claim (Tennessee) · Go Syfert
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wrongful death claim in Tennessee

30 Tennessee opinions name it 2 courts 1996–2026 2 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 (19)

CaseFollowedCited
Kline v. Eyrichgreen
tenn · 2002 · cited in 3 Tennessee opinions naming this issue, 2016–2024
2 sentences

2024“Stated another way, ‘[t]here can be but one cause of action for the wrongful death of another.’” Id. (quoting Kline, 69 S.W.3d at 207 ). “[M]ultiple actions may not be brought to resolve a single wrongful death claim.” Id. at 318 .

2024“Stated another way, ‘[t]here can be but one cause of action for the wrongful death of another.’” Id. (quoting Kline, 69 S.W.3d at 207 ). “[M]ultiple actions may not be brought to resolve a single wrongful death claim.” Id. at 318 .

33
Foster v. Jeffersgreen
tennctapp · 1991 · cited in 3 Tennessee opinions naming this issue, 2002–2016
2 sentences

2016In a dispute between the surviving spouse and the children of the decedent as to who may maintain the action, the surviving spouse clearly has “the prior and superior right above all others . . . .” Foster v. Jeffers, 813 S.W.2d 449, 451 (Tenn. Ct. App. 1991); see also Tenn. Code Ann. § 20-5-107 (1994); Busby v. Massey, 686 S.W.2d 60, 62 (Tenn. 1984).

2016In a dispute between the surviving spouse and the children of the decedent as to who may maintain the action, the surviving spouse clearly has “the prior and superior right above all others . . . .” Foster v. Jeffers, 813 S.W.2d 449, 451 (Tenn. Ct. App. 1991); see also Tenn. Code Ann. § 20-5-107 (1994); Busby v. Massey, 686 S.W.2d 60, 62 (Tenn. 1984).

33
Busby v. Masseygreen
tenn · 1984 · cited in 3 Tennessee opinions naming this issue, 2002–2016
2 sentences

2016In a dispute between the surviving spouse and the children of the decedent as to who may maintain the action, the surviving spouse clearly has “the prior and superior right above all others . . . .” Foster v. Jeffers, 813 S.W.2d 449, 451 (Tenn. Ct. App. 1991); see also Tenn. Code Ann. § 20-5-107 (1994); Busby v. Massey, 686 S.W.2d 60, 62 (Tenn. 1984).

2016In a dispute between the surviving spouse and the children of the decedent as to who may maintain the action, the surviving spouse clearly has “the prior and superior right above all others . . . .” Foster v. Jeffers, 813 S.W.2d 449, 451 (Tenn. Ct. App. 1991); see also Tenn. Code Ann. § 20-5-107 (1994); Busby v. Massey, 686 S.W.2d 60, 62 (Tenn. 1984).

33
Matthews v. Mitchellgreen
tennctapp · 1985 · cited in 2 Tennessee opinions naming this issue, 2001–2015
2 sentences

2015“Because multiple actions may not be brought to resolve a single wrongful death claim, the statutes carefully prescribe the priority of those 9 who may assert the action on behalf of the decedent and any other beneficiaries.” Id.

2001See also Matthews v. Mitchell, 705 S.W.2d 657, 660 (Tenn. Ct. App. 1985) (stating that “there can be but one cause of action for the wrongful death of another”).

12
Jones Ex Rel. Bell v. Blackgreen
tenn · 1976 · cited in 2 Tennessee opinions naming this issue, 2001–2001
2 sentences

2001In so holding, we reaffirm Jones v. Black, 539 S.W.2d 123 *333 (Tenn.1976), in which this Court held that the statute of limitations for a wrongful death claim is not tolled during the minority of the decedent’s children.

2001In so holding, we reaffirm Jones v. Black, 539 S.W.2d 123 (Tenn. 1976), in which this Court held that the statute of limitations for a wrongful death claim is not tolled during the minority of the decedent’s children.

12
Christopher O'Dneal v. Baptist Memorial Hospital-Tiptongreen
· 2018 · cited in 1 Tennessee opinions naming this issue, 2024–2024
2 sentences

2024However, it ultimately concluded that “although only one cause of action for wrongful death may be maintained – that is, the claim is indivisible – each statutory beneficiary asserts the wrongful death claim on their own behalf.” Id. at *5 (citing O’Dneal, 556 S.W.3d at 771). “[E]ach statutory beneficiary ‘may recover damages for their losses suffered as a result of the death as well as damages sustained by the deceased from the time of injury to the time of death.’” Id. (quoting Beard, 528 S.W.3d at 498 ).

2024However, it ultimately concluded that “although only one cause of action for wrongful death may be maintained – that is, the claim is indivisible – each statutory beneficiary asserts the wrongful death claim on their own behalf.” Id. at *5 (citing O’Dneal, 556 S.W.3d at 771). “[E]ach statutory beneficiary ‘may recover damages for their losses suffered as a result of the death as well as damages sustained by the deceased from the time of injury to the time of death.’” Id. (quoting Beard, 528 S.W.3d at 498 ).

11
Sharpe v. City of Lewisburg, Tenn.green
tnmd · 1988 · cited in 1 Tennessee opinions naming this issue, 2020–2020
1 sentence

2020Tenn.) rev’d in part 557 F.3d 311 (6th Cir. 2009) (awarding $75,000, after a bench trial on a wrongful death claim, for conscious pain and suffering by a drowning victim who “undoubtedly experienced excruciating pain and terror as he struggled to stay afloat and to breathe” but only for a period of ten minutes); Sharpe v. City of Lewisburg, Tenn., 677 F. Supp. 1362, 1365 (M.D.

11
Estate of Baker Ex Rel. Baker v. Maplesgreen
tennctapp · 1999 · cited in 1 Tennessee opinions naming this issue, 2015–2015
1 sentence

2015Once the priority or right to assert the wrongful death claim is established and the lawsuit is filed, the party with the statutory authority maintains “complete control over the right of action until he or she waives that right.” Estate of Baker ex rel. v. Maples, 995 S.W.2d 114, 115 (Tenn. Ct. App. 1999) (citations omitted).

11
Rogers v. Donelson-Hermitage Chamber of Commercegreen
tennctapp · 1990 · cited in 1 Tennessee opinions naming this issue, 2015–2015
1 sentence

2015That is a health care liability question.” 3In Sister‟s deposition, however, she stated that she “did not tell them [Brother] had tuberculosis . . . [she] did not know for all those years that [Brother] had tuberculosis.” She related she “told them about the oxygen.” 4Under Tennessee law, a wrongful death claim “does not create a new cause of action for the plaintiff[], but simply preserves [the decedent‟s] right of action which would otherwise be extinguished by [his] death.” Rogers v. Donelson-Hermitage Chamber of Commerce, 807 S.W.2d 242, 245 (Tenn. Ct. App. 1990); See also Tenn. Code Ann.

11
Lawrence Ex Rel. Powell v. Stanfordgreen
tenn · 1983 · cited in 1 Tennessee opinions naming this issue, 2014–2014
1 sentence

2014Dulin v. Dulin, No. W2001-02969-COA-R3-CV, 2003 WL 22071454 , at *4 (Tenn. Ct. App. Sept. 3, 2003); Lawrence v. Stanford, 655 S.W.2d 927, 929 (Tenn. 1983)).

11
Rolen v. Wood Presbyterian Home, Inc.green
tennctapp · 2005 · cited in 1 Tennessee opinions naming this issue, 2009–2009
1 sentence

2009P. 8.01; Rolen v. Wood Presbyterian Home, Inc., 174 S.W.3d 158, 161-62 (Tenn.Ct.App.2005); see also Gipson, supra, (suggesting that a survival claim for personal injuries and a wrongful death claim could be brought in the same action so long as the personal injury action was properly revived).

11
Smith v. Goregreen
tenn · 1987 · cited in 1 Tennessee opinions naming this issue, 2008–2008
1 sentence

2008See Smith v. Gore, 728 S.W.2d 738, 741 (Tenn. 1987) (holding that wrongful birth actions are actions by parents “on their own behalf”).

11
Hataway v. McKinleygreen
tenn · 1992 · cited in 1 Tennessee opinions naming this issue, 2003–2003
1 sentence

2003See Hataway v. McKinley, 830 S.W.2d 53, 54 (Tenn.1992) (applying “most significant relationship” test to determine which state’s substantive law would apply to the wrongful death claim).

11
Hawthorne v. Lankesgreen
tennctapp · 1968 · cited in 1 Tennessee opinions naming this issue, 1999–1999
1 sentence

1999The court noted, “In substance, we are considering a wrongful death claim and a personal injury claim on behalf of two passengers in a vehicle against two defendants . . . .” Id.; see also Hawthorne v. Lankes, 430 S.W.2d 803, 805 (Tenn. App. 1968) (finding special interrogatories were not necessary because the issues were neither complex nor involved).

11
Shivers v. Ramseygreen
tennctapp · 1996 · cited in 1 Tennessee opinions naming this issue, 1999–1999
2 sentences

1999Co., 138 Tenn. 161 , 196 S.W. 492 , 497 (1917) (permitting the res ipsa inference in a personal injury suit brought by the estates of two deceased employees for a construction accident); Shivers v. Ramsey, 937 S.W.2d 945, 948-49 (Tenn. Ct. App.1996) (applying res ipsa loquitur in personal injury case arising from an automobile accident); Collins Chapel Connectional Hosp., 696 S.W.2d at 20-21 (holding res ipsa loquitur to apply in a wrongful death claim against the defendant nursing home); Roberts v. Ray, 45 Tenn.App. 280 , 322 S.W.2d 435, 437 (1959) (applying res ipsa loquitur in negligence ac

1999Co., 138 Tenn. 161 , 196 S.W. 492 , 497 (1917) (permitting the res ipsa inference in a personal injury suit brought by the estates of two deceased employees for a construction accident); Shivers v. Ramsey, 937 S.W.2d 945, 948-49 (Tenn. Ct. App.1996) (applying res ipsa loquitur in personal injury case arising from an automobile accident); Collins Chapel Connectional Hosp., 696 S.W.2d at 20-21 (holding res ipsa loquitur to apply in a wrongful death claim against the defendant nursing home); Roberts v. Ray, 45 Tenn.App. 280 , 322 S.W.2d 435, 437 (1959) (applying res ipsa loquitur in negligence ac

11
Roberts v. Raygreen
tennctapp · 1958 · cited in 1 Tennessee opinions naming this issue, 1999–1999
11
Franklin v. Collins Chapel Connectional Hospitalgreen
tennctapp · 1985 · cited in 1 Tennessee opinions naming this issue, 1999–1999
2 sentences

1999Co., 138 Tenn. 161 , 196 S.W. 492 , 497 (1917) (permitting the res ipsa inference in a personal injury suit brought by the estates of two deceased employees for a construction accident); Shivers v. Ramsey, 937 S.W.2d 945, 948-49 (Tenn. Ct. App.1996) (applying res ipsa loquitur in personal injury case arising from an automobile accident); Collins Chapel Connectional Hosp., 696 S.W.2d at 20-21 (holding res ipsa loquitur to apply in a wrongful death claim against the defendant nursing home); Roberts v. Ray, 45 Tenn.App. 280 , 322 S.W.2d 435, 437 (1959) (applying res ipsa loquitur in negligence ac

1999Co., 138 Tenn. 161 , 196 S.W. 492 , 497 (1917) (permitting the res ipsa inference in a personal injury suit brought by the estates of two deceased employees for a construction accident); Shivers v. Ramsey, 937 S.W.2d 945, 948-49 (Tenn. Ct. App.1996) (applying res ipsa loquitur in personal injury case arising from an automobile accident); Collins Chapel Connectional Hosp., 696 S.W.2d at 20-21 (holding res ipsa loquitur to apply in a wrongful death claim against the defendant nursing home); Roberts v. Ray, 45 Tenn.App. 280 , 322 S.W.2d 435, 437 (1959) (applying res ipsa loquitur in negligence ac

11
Sullivan v. Crabtreegreen
tennctapp · 1953 · cited in 1 Tennessee opinions naming this issue, 1999–1999
11
Murphy v. Schwartzgreen
tennctapp · 1986 · cited in 1 Tennessee opinions naming this issue, 1999–1999
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 (15)

CaseCitedYears
Linda Beard v. James William Branson green
· 2017
2 sentences

2026While the Defendants are correct that the decedent’s estate is not the claimant, id., they have overlooked the crux of the trial court’s reasoning, which is that the wrongful death claim is singular and indivisible.

2024“Thus, while a wrongful death claim may be indivisible,” we explained, “in the absence of statutory language giving one party dominance over another, the parties are not one undivided entity proceeding on behalf of the decedent or estate; rather, each asserts the wrongful death claim on their own behalf.” Id. (italicization added).

22024–2026
Jeremy Flax v. Daimler-Chrysler Corporation green
tenn · 2008
2 sentences

2017Id. at 529 .

2017Id. at 530 .

22013–2017
Johnson v. Oman Construction Company, Inc. green
tenn · 1975
2 sentences

2014Id. at 784 .

1996Id. at 784 .

21996–2014
Hodges v. S.C. Toof & Co. green
tenn · 1992
2 sentences

2008Toof & Co., 833 S.W.2d 896 (Tenn. 1992), the trial court reduced the punitive damages award on the wrongful death claim from $66,500,000 to $13,367,345 and the punitive damages award on Ms. Sparkman’s negligent infliction of emotional distress claim from $32,500,000 to $6,632,655.

2008Toof & Co., 833 S.W.2d 896 (Tenn.1992), the trial court reduced the punitive damages award on the wrongful death claim from $66,500,000 to $13,367,345 and the punitive damages award on Ms. Sparkman’s negligent infliction of emotional distress claim from $32,500,000 to $6,632,655.

22008–2008
Beam v. Maryland Casualty Co. green
tenn · 1972
2 sentences

1999It should also be noted that Sexton relied upon the case of Beam v. Maryland Casualty Co., 477 S.W.2d 510 (Tenn. 1972), a Supreme Court case holding that the employer’s subrogation rights under T.C.A. § 50- Page 4 914 (now T.C.A. § 50-6-112) extend to that portion of a settlement of a wrongful death claim that inures to the benefit of the children of the deceased employee.

1999It should also be noted that Sexton relied upon the case of Beam v. Maryland Casualty Co., 477 S.W.2d 510 (Tenn. 1972), a Supreme Court case holding that the employer’s subrogation rights under T.C.A. § 50- Page 4 914 (now T.C.A. § 50-6-112) extend to that portion of a settlement of a wrongful death claim that inures to the benefit of the children of the deceased employee.

21999–1999
Jordan v. Baptist Three Rivers Hospital green
tenn · 1999
2 sentences

1999If the wrongful death claim is authorized under “survival” legislation, then it is clear that a wrongful death recovery is, in the language of the subrogation statute, a “ recovery...by those to whom such worker’s right of action survives.” I believe that Jordan necessarily changes the ruling in Beam because Jordan clearly holds that the Tennessee wrongful death statutory scheme, in addition to authorizing a survival action, “creates a cause of action that compensates survivors for their losses.” Jordan, 984 S.W.2d at 598 .

1999If the wrongful death claim is authorized under “survival” legislation, then it is clear that a wrongful death recovery is, in the language of the subrogation statute, a “ recovery...by those to whom such worker’s right of action survives.” I believe that Jordan necessarily changes the ruling in Beam because Jordan clearly holds that the Tennessee wrongful death statutory scheme, in addition to authorizing a survival action, “creates a cause of action that compensates survivors for their losses.” Jordan, 984 S.W.2d at 598 .

21999–1999
Francis Ione Lethcoe v. Ricky Ray Holden, et ux green
tennctapp · 2000
1 sentence

2020While Lethcoe involved a commercial tenant and a plaintiff asserting a wrongful death claim, see 31 S.W.3d at 255-56 , its principles have been applied in cases involving a residential tenant’s premises liability claim.

12020–2020
Matheny Ex Rel. Matheny v. Tennessee Valley Authority green
ca6 · 2009
1 sentence

2020Tenn.) rev’d in part 557 F.3d 311 (6th Cir. 2009) (awarding $75,000, after a bench trial on a wrongful death claim, for conscious pain and suffering by a drowning victim who “undoubtedly experienced excruciating pain and terror as he struggled to stay afloat and to breathe” but only for a period of ten minutes); Sharpe v. City of Lewisburg, Tenn., 677 F. Supp. 1362, 1365 (M.D.

12020–2020
Edgar Foster, Individually and on Behalf of Wife, and Stanley Turner v. St. Joseph Hospital, Mahir R. Awdeh, M.D., Raj. C. Dave, M.D. green
tennctapp · 2004
1 sentence

2016Given these policy considerations and the fact that “„the cause of action is not changed by the substitution of the proper party plaintiff for the improper plaintiff and that such a substitution does not prejudice the defendant who has had notice from the beginning of the suit,‟” Id. at *4 (quoting Foster, 158 S.W.3d at 424 ), the Holley Court held that the trial court erred in dismissing the wrongful death claim.

12016–2016
State Farm Mutual Automobile Insurance v. Campbell green
scotus · 2003
1 sentence

2008It is sufficient that the statutory definition of reckless homicide encompasses the conduct of DCC. -16- of the civil process to assess criminal penalties that can be imposed only after the heightened protections of a criminal trial have been observed.” Campbell, 538 U.S. at 428 .

12008–2008
Gipson v. Memphis Street Railway Co. green
tennctapp · 1962
2 sentences

2005Gipson v. Memphis Street Railway Co., 51 Tenn.App. 31 , 364 S.W.2d 110 (1962).

2005Gipson v. Memphis Street Railway Co., 51 Tenn.App. 31 , 364 S.W.2d 110 (1962).

12005–2005
Kirksey v. Overton Pub, Inc. green
tennctapp · 1990
1 sentence

2003A third case cited by defendants, Kirksey, 804 S.W.2d 68 , involved a wrongful death claim for the death of an adult from the effects of ten or more “Zombies” consumed, on a bet, within a short period of time.

12003–2003
Collier v. Memphis Light, Gas & Water Division green
tennctapp · 1983
1 sentence

2001See Tenn. Code Ann. § 28-1-106 (1980); Collier, 657 S.W.2d at 773 .

12001–2001
Hill v. City of Germantown green
tenn · 2000
1 sentence

2001In Hill, the supreme court held that, “loss of consortium damages in a wrongful death claim are wholly contained within the award for wrongful death.” Id. at 240 .

12001–2001
North Memphis Sav. Bank v. Union Bridge & Construction Co. green
· 1917
11999–1999

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 20-5-106 (10) TN § Tenn. Code Ann. § 20-5-113 (10) TN § Tenn. Code Ann. § 20-5-107 (7) TN § Tenn. Code Ann. § 20-5-110 (5) TN § Tenn. Code Ann. § 29-20-201 (4) TN § Tenn. Code Ann. § 31-2-104 (4) TN § Tenn. Code Ann. § 20-5-102 (3) TN § Tenn. Code Ann. § 20-5-103 (3) TN § Tenn. Code Ann. § 29-20-205 (3) TN § Tenn. Code Ann. § 29-20-305 (3) TN § Tenn. Code Ann. § 29-26-101 (3) TN § Tenn. Code Ann. § 31-2-105 (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

OH 157 (1959–2025) IL 127 (1962–2026) TX 117 (1973–2026) CA 103 (1958–2026) NY 91 (1949–2025) LA 71 (1964–2024) MS 68 (1984–2026) GA 62 (1967–2024) MO 60 (1973–2024) FL 60 (1967–2025) AL 58 (1984–2025) MD 53 (1981–2025) PA 52 (1983–2025) IN 52 (1982–2025) AZ 38 (1965–2025) NM 37 (1970–2025) KY 36 (1990–2026) WA 34 (1974–2026) NC 33 (1971–2022) MI 32 (1969–2022) WI 32 (1979–2026) NJ 31 (1978–2024) TN 30 (1996–2026) OR 28 (1986–2026) WV 26 (1973–2021) CO 25 (1977–2026) IA 25 (1983–2026) MN 23 (1982–2024) MA 21 (1962–2024) CT 19 (1992–2022) KS 17 (1969–2026) AR 16 (1997–2022) VA 15 (1980–2024) SC 14 (2010–2025) UT 14 (1983–2025) MT 13 (1968–2013) OK 13 (1975–2024) SD 10 (1974–2022) ID 9 (1980–2024) WY 8 (1989–2021) ME 8 (1999–2025) HI 7 (1998–2025) AK 6 (1986–2020) DC 6 (1980–2006) RI 5 (1991–2019) ND 5 (1988–2019) NE 5 (1988–2024) NV 5 (1991–2023) DE 5 (1984–2021) VI 2 (2014–2016) VT 2 (2005–2020)

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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