intervening cause doctrine (Tennessee) · Go Syfert
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intervening cause doctrine in Tennessee

16 Tennessee opinions name it 5 courts 2000–2019 0 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 (11)

CaseFollowedCited
Rains v. Bend of the Rivergreen
tennctapp · 2003 · cited in 5 Tennessee opinions naming this issue, 2006–2019
2 sentences

2019It noted that Tennessee courts "have consistently recognized that the independent intervening cause doctrine may properly be invoked in cases involving self-inflicted injury or death." (Quoting Rains v. Bend of the River , 124 S.W.3d 580 , 593 (Tenn. Ct. App. 2003) ).

2019Servs. , 488 F.3d 721 , 737-38 (6th Cir. 2007) (viewing Tennessee's suicide rule as "parsimonious" but firmly established); Rains , 124 S.W.3d at 593 ("Tennessee's courts, like other state and federal courts, have consistently recognized that the independent intervening cause doctrine may properly be invoked in cases involving self-inflicted injury or death." (footnote omitted)).

55
Waste Management, Inc. v. South Central Bell Telephone Co.green
tennctapp · 1997 · cited in 4 Tennessee opinions naming this issue, 2001–2006
2 sentences

2006Co., 15 S.W.3d 425, 432 (Tenn.Ct.App.1997).

2002In Waste Management, Inc. of Tennessee v. South Central Bell Telephone Company , 15 S.W.3d 425, 432 (Tenn. Ct. App. 1997) we described the intervening cause doctrine as follows: The intervening cause doctrine is a common-law liability shifting device.

24
Weathers v. Pilkintongreen
tennctapp · 1988 · cited in 2 Tennessee opinions naming this issue, 2000–2003
2 sentences

2003White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn.Ct.App.1988).

2000White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn. Ct. App. 1988).

22
Lancaster v. Montesigreen
tenn · 1965 · cited in 2 Tennessee opinions naming this issue, 2000–2003
2 sentences

2003White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn.Ct.App.1988).

2003White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn.Ct.App.1988).

22
Jones v. Stewartgreen
tenn · 1946 · cited in 2 Tennessee opinions naming this issue, 2000–2003
2 sentences

2003White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn.Ct.App.1988).

2003White v. Lawrence, 975 S.W.2d at 530 ; Lancaster v. Montesi, 216 Tenn. 50, 58 , 390 S.W.2d 217, 221 (1965); Jones v. Stewart, 183 Tenn. 176, 180-81 , 191 S.W.2d 439, 440 (1946); Weathers v. Pilkinton, 754 S.W.2d 75, 78 (Tenn.Ct.App.1988).

22
White Ex Rel. Estate of White v. Lawrencegreen
tenn · 1998 · cited in 3 Tennessee opinions naming this issue, 2000–2006
2 sentences

2006App.2003); White v. Lawrence, 975 S.W.2d 525, 529 (Tenn.1998).

2006The intervening cause doctrine operates to relieve a negligent actor from liability “when a new, independent and unforeseen cause intervenes to produce a result that the negligent actor could not have reasonably foreseen.” Rains v. Bend of the River, 124 S.W.3d 580, 593 (Tenn.Ct.App.2003); White v. Lawrence, 975 S.W.2d 525, 529 (Tenn.1998).

13
Hercules, Inc. v. Stevens Shipping Co., Aetna Casualty & Surety Company, Third Partygreen
ca3 · 1985 · cited in 1 Tennessee opinions naming this issue, 2006–2006
2 sentences

2006See Holden v. Balko, 949 F.Supp. 704, 708-09 (S.D.Ind.1996) (discussing the relationship of the intervening cause doctrine and the “all-or-nothing” approach of the common-law rule of joint and several liability); Christlieb, supra, at 165 (classifying superseding causes under three general types, defining an “absorbing cause” as one “that, for one reason or another, is judged to be much more at fault than the other proximate cause,” and stating that this type of superseding cause “has no logical use under comparative [negligence] systems”); see also Hercules, Inc. v. Stevens Shipping Co., 765

2006See Holden v. Balko, 949 F.Supp. 704, 708-09 (S.D.Ind.1996) (discussing the relationship of the intervening cause doctrine and the “all-or-nothing” approach of the common-law rule of joint and several liability); Christlieb, supra, at 165 (classifying superseding causes under three general types, defining an “absorbing cause” as one “that, for one reason or another, is judged to be much more at fault than the other proximate cause,” and stating that this type of superseding cause “has no logical use under comparative [negligence] systems”); see also Hercules, Inc. v. Stevens Shipping Co., 765

11
Perez v. McConkeygreen
tenn · 1994 · cited in 1 Tennessee opinions naming this issue, 2006–2006
2 sentences

2006In Perez v. McConkey, our Supreme Court, abolishing the doctrine of implied assumption of risk, noted that "it would be ironic indeed if, after abolishing the all-or-nothing proposition of contributory negligence in McIntyre [v. Balentine, 833 S.W.2d 52 ], we were to reinstate it here using the vehicle of assumption of risk." Perez, 872 S.W.2d 897, 905 (Tenn.1994).

2006In Perez v. McConkey, our Supreme Court, abolishing the doctrine of implied assumption of risk, noted that “it would be ironic indeed if, after abolishing the all-or-nothing proposition of contributory negligence in McIntyre [v. Balentine, 838 S.W.2d 52 ], we were to reinstate it here using the vehicle of assumption of risk.” Perez, 872 S.W.2d 897, 905 (Tenn.1994).

11
Holden v. Balkogreen
insd · 1996 · cited in 1 Tennessee opinions naming this issue, 2006–2006
2 sentences

2006See Holden v. Balko, 949 F.Supp. 704, 708-09 (S.D.Ind.1996) (discussing the relationship of the intervening cause doctrine and the “all-or-nothing” approach of the common-law rule of joint and several liability); Christlieb, supra, at 165 (classifying superseding causes under three general types, defining an “absorbing cause” as one “that, for one reason or another, is judged to be much more at fault than the other proximate cause,” and stating that this type of superseding cause “has no logical use under comparative [negligence] systems”); see also Hercules, Inc. v. Stevens Shipping Co., 765

2006See Holden v. Balko, 949 F.Supp. 704, 708-09 (S.D.Ind.1996) (discussing the relationship of the intervening cause doctrine and the “all-or-nothing” approach of the common-law rule of joint and several liability); Christlieb, supra, at 165 (classifying superseding causes under three general types, defining an “absorbing cause” as one “that, for one reason or another, is judged to be much more at fault than the other proximate cause,” and stating that this type of superseding cause “has no logical use under comparative [negligence] systems”); see also Hercules, Inc. v. Stevens Shipping Co., 765

11
Staples v. CBL & Associates, Inc.green
tenn · 2000 · cited in 1 Tennessee opinions naming this issue, 2002–2002
1 sentence

2002In Staples v. CBL & Associates, Inc., 15 S.W.3d 83, 89 (Tenn. 2000) the Tennessee Supreme Court set forth the standard of review appropriate to summary judgments as follows: The standards governing the assessment of evidence in the summary judgment context are also well established.

11
Goad v. Stategreen
tenn · 1996 · cited in 1 Tennessee opinions naming this issue, 2001–2001
1 sentence

2001See Goad, 938 S.W.2d at 369 .

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 (7)

CaseCitedYears
Anderson v. Westfield Group green
tenn · 2008
2 sentences

2017Application of the intervening cause principle is not an affirmative defense but, rather, is a “way of assessing the scope of an employer’s liability for injuries occurring after a compensable injury.” Id. at 697 ; see Shelton v. Cent.

2017Id.

32016–2017
Macdermid v. Discover Financial Services green
ca6 · 2007
2 sentences

2019Servs., 488 F.3d 721 , 737-38 (6th Cir. 2007) (viewing Tennessee’s suicide rule as “parsimonious” but firmly established); Rains, 124 S.W.3d at 593 (“Tennessee’s courts, like other state and federal courts, have consistently recognized that the independent intervening cause doctrine may properly be invoked in cases involving self-inflicted injury or death.” (footnote omitted)).

2019Servs. , 488 F.3d 721 , 737-38 (6th Cir. 2007) (viewing Tennessee's suicide rule as "parsimonious" but firmly established); Rains , 124 S.W.3d at 593 ("Tennessee's courts, like other state and federal courts, have consistently recognized that the independent intervening cause doctrine may properly be invoked in cases involving self-inflicted injury or death." (footnote omitted)).

22019–2019
Whitehead v. Dycho Co., Inc. green
tenn · 1989
1 sentence

2011These are two separate and distinct doctrines; the application of the former does not indicate an adoption of the latter. 18 The learned intermediary doctrine was likewise not adopted in Whitehead, 775 S.W.2d 593 .

12011–2011
Jones v. Huey green
tenn · 1962
1 sentence

2008In one case, for example, we stated that “it will be found that if the injured employee, knowing of his weakness, rashly undertakes to do things likely to result in harm to himself, the chain of causation is broken by his own negligence.” Jones, 357 S.W.2d at 49 .

12008–2008
McIntyre v. Balentine green
tenn · 1992
1 sentence

2006In Perez v. McConkey, our Supreme Court, abolishing the doctrine of implied assumption of risk, noted that "it would be ironic indeed if, after abolishing the all-or-nothing proposition of contributory negligence in McIntyre [v. Balentine, 833 S.W.2d 52 ], we were to reinstate it here using the vehicle of assumption of risk." Perez, 872 S.W.2d 897, 905 (Tenn.1994).

12006–2006
Torres v. El Paso Electric Co. green
nm · 1999
1 sentence

2006By footnote, that Court observed: Due to the broad scope of the doctrine of independent intervening cause, we expressly limit our analysis of its relationship to comparative negligence to those negligent acts or omissions by a third party or the plaintiff that are causes in fact of the plaintiffs injury; our analysis does not extend to intentional tortious or criminal acts or forces of nature. 987 P.2d at 392 n. 2.

12006–2006
Chamberland v. Roswell Osteopathic Clinic, Inc. green
nmctapp · 2001
2 sentences

2006While the superseding cause doctrine, and particularly its use in jury instructions, appears to be moving ever closer to a merger into proximate causation, Waste Mgmt., Inc., 15 S.W.3d 425 ; Chamberland v. Roswell Osteopathic Clinic, Inc., 130 N.M..532, 27 P.3d 1019 (N.M.Ct.App.2001), it still retains its separate identity in most jurisdictions that have adopted a comparative fault system.

2006We hold that the jury in this case should not have been instructed on independent intervening cause, and we reverse the defense verdict and remand for a new trial. 27 P.3d at 1020 .

12006–2006

Statutes the citing opinions construe

USC § 18u.s.c.922 (4) TN § Tenn. Code Ann. § 29-28-102 (3) TN § Tenn. Code Ann. § 29-28-105 (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

CO 17 (1997–2026) TN 16 (2000–2019) NM 13 (1976–2022) CT 8 (1995–2007) IL 6 (2014–2025) FL 6 (1988–2012) KS 5 (1943–2025) WV 4 (2016–2020) MA 3 (1995–2007) OH 2 (1996–2007) MT 2 (2002–2006) WY 2 (1995–2011) NC 2 (1951–1995) MD 2 (1975–2024) IN 2 (1994–2002) DC 2 (1979–1979)

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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