legal basis claim (Tennessee) · Go Syfert
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legal basis claim in Tennessee

16 Tennessee opinions name it 3 courts 2015–2026 5 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 (7)

CaseFollowedCited
Brenda Benz-Elliott v. Barrett Enterprises, LPgreen
tenn · 2015 · cited in 12 Tennessee opinions naming this issue, 2015–2026
2 sentences

2026To determine the gravamen of a claim, a court "must first consider the legal basis of the claim and then consider the type of injuries for which damages are sought." Benz-Elliott v. Barrett Enters., LP, 456 S.W.3d 140, 151 (Tenn. 2015) (citation omitted).

2025The Benz-Elliott Court clarified that a two-step approach of (1) “consider[ing] the legal basis of the claim” and (2) “then consider[ing] the type of injuries for which damages are sought” “is the correct framework for courts to employ when ascertaining the gravamen of a claim for the purpose of choosing the applicable statute of limitations.” Id. at 151 .

512
Williams v. Thompsongreen
tenn · 1969 · cited in 2 Tennessee opinions naming this issue, 2015–2022
2 sentences

2022Id. at 449.

2015Id. at 449. 8 Even when more than one cause of action was alleged in a single complaint, language in prior decisions of this Court seemed to suggest that the complaint should be distilled to a single “gravaman” based on the type of damages requested.

22
William Thomas McFarland v. Michael S. Pembertongreen
· 2017 · cited in 2 Tennessee opinions naming this issue, 2018–2026
2 sentences

2026This Court previously held that the gravamen analysis requires consideration of (1) “the legal basis of the claim” and (2) “the type of injuries for which damages are sought.” Id. at 151–52 (citation omitted) (noting that ascertaining the gravamen is a fact-intensive inquiry); see also McFarland v. Pemberton, 530 S.W.3d 76 , 109–10 (Tenn. 2017).

2018“To determine the gravamen of a claim . . . ‘a court must first consider the legal basis of the claim and then consider the type of injuries for which damages are sought.’” Id. (quoting Benz-Elliot v. Barrett Enters., L.P., 456 S.W.3d 140, 151 (Tenn. 2015)).

12
Norman Redwing v. Catholic Bishop for the Diocese of Memphisgreen
tenn · 2012 · cited in 2 Tennessee opinions naming this issue, 2022–2026
2 sentences

2026This Court previously held that the gravamen analysis requires consideration of (1) “the legal basis of the claim” and (2) “the type of injuries for which damages are sought.” Id. at 151–52 (citation omitted) (noting that ascertaining the gravamen is a fact-intensive inquiry); see also McFarland v. Pemberton, 530 S.W.3d 76 , 109–10 (Tenn. 2017).

2022The gravamen “does not involve the ‘designation’ or ‘form’ of the action,” Redwing v. Catholic Bishop for the Diocese of Memphis, 363 S.W.3d 436, 457 (Tenn. 2012) (quoting Pera v. Kroger Co., 674 S.W.2d 715, 719 (Tenn. 1984); Callaway v. McMillian, 58 Tenn. 557 , 559 (1872)), and courts must consider both the legal basis of the claim and the type of injuries for which damages are sought.

12
Pera v. Kroger Co.green
tenn · 1984 · cited in 1 Tennessee opinions naming this issue, 2022–2022
1 sentence

2022The gravamen “does not involve the ‘designation’ or ‘form’ of the action,” Redwing v. Catholic Bishop for the Diocese of Memphis, 363 S.W.3d 436, 457 (Tenn. 2012) (quoting Pera v. Kroger Co., 674 S.W.2d 715, 719 (Tenn. 1984); Callaway v. McMillian, 58 Tenn. 557 , 559 (1872)), and courts must consider both the legal basis of the claim and the type of injuries for which damages are sought.

11
State v. Prestongreen
tenn · 1988 · cited in 1 Tennessee opinions naming this issue, 2020–2020
1 sentence

2020Defendant bears the burden of “reserving articulating, and identifying the issue[.]” Pendergrass, 937 S.W.2d at 838 . “[T]he [certified] question of law must be stated so as to clearly identify the scope and the limits of the legal issue reserved.” Preston, 759 S.W.2d at 650 (emphasis added).

11
Resolution Trust Corp. v. Woodgreen
tnwd · 1994 · cited in 1 Tennessee opinions naming this issue, 2015–2015
1 sentence

2015See also Resolution Trust Corp. v. Wood, 870 F.Supp. 797, 807 (W.D.Tenn. 1994) (explaining that, when determining the gravamen of a claim, Tennessee law requires courts to consider the cause of the injury, and holding that some claims were governed by the three-year statute of limitations while others were governed by the six-year statute of limitations).

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 (2)

CaseCitedYears
Callaway v. McMillian green
tenn · 1872
1 sentence

2022The gravamen “does not involve the ‘designation’ or ‘form’ of the action,” Redwing v. Catholic Bishop for the Diocese of Memphis, 363 S.W.3d 436, 457 (Tenn. 2012) (quoting Pera v. Kroger Co., 674 S.W.2d 715, 719 (Tenn. 1984); Callaway v. McMillian, 58 Tenn. 557 , 559 (1872)), and courts must consider both the legal basis of the claim and the type of injuries for which damages are sought.

12022–2022
State v. Pendergrass green
tenn · 1996
1 sentence

2020Defendant bears the burden of “reserving articulating, and identifying the issue[.]” Pendergrass, 937 S.W.2d at 838 . “[T]he [certified] question of law must be stated so as to clearly identify the scope and the limits of the legal issue reserved.” Preston, 759 S.W.2d at 650 (emphasis added).

12020–2020

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 28-3-109 (9) TN § Tenn. Code Ann. § 28-3-105 (8) TN § Tenn. Code Ann. § 28-3-104 (4)

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

CA 45 (1941–2026) TX 34 (1963–2026) FL 22 (1991–2024) TN 16 (2015–2026) IL 15 (1889–2026) OK 14 (1997–2023) UT 11 (1988–2020) MI 10 (1907–2025) CO 8 (1988–2025) MN 8 (1986–2002) NY 6 (1988–2016) NV 6 (2011–2020) MA 5 (1997–2025) MO 4 (1994–2025) NC 3 (1993–2019) PA 3 (1973–2026) WA 3 (1994–2025) OR 3 (2019–2023) MS 2 (2009–2019) WI 2 (1994–2010) AL 2 (1989–2005) ND 2 (2010–2010) CT 2 (1992–2020) LA 2 (1992–1993) NJ 2 (1959–2006) NM 2 (1971–2024)

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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