three-factor analysis (Tennessee) · Go Syfert
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three-factor analysis in Tennessee

7 Tennessee opinions name it 2 courts 1999–2024 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 (9)

CaseFollowedCited
In Re Rgbgreen
haw · 2010 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

11
State v. Anonymousgreen
conn · 1979 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

11
In Re ARASgreen
gactapp · 2006 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

11
J.B., Etc. v. Florida Department of Children and Familiesgreen
fla · 2015 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

11
Barber & McMurry, Inc. v. Top-Flite Development Corp.green
tennctapp · 1986 · cited in 1 Tennessee opinions naming this issue, 2007–2007
1 sentence

2007Corp. Inc., 720 S.W.2d 469, 471 (Tenn. Ct. App. 1986) (Defense counsel knew the trial date, but elected not to attend trial because he had another trial scheduled in a different county.). -3- conduct that is flagrant and unexplained.4 This view of willfulness finds further support from the United States Court of Appeals for the Second Circuit, setting forth the willfulness standard which our Supreme Court adopted in Barbee.

11
Davis v. Muslergreen
ca2 · 1983 · cited in 1 Tennessee opinions naming this issue, 2007–2007
2 sentences

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

11
Campbell v. Archergreen
tenn · 1977 · cited in 1 Tennessee opinions naming this issue, 2007–2007
2 sentences

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

11
Tennessee Department of Human Services v. Barbeegreen
tenn · 1985 · cited in 1 Tennessee opinions naming this issue, 2007–2007
2 sentences

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

11
Masada Investment Corp. v. Allengreen
tenn · 1985 · cited in 1 Tennessee opinions naming this issue, 1999–1999
1 sentence

1999See Masada, 697 S.W.2d at 334 .

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 (6)

CaseCitedYears
Chevron Oil Co. v. Huson red
scotus · 1971
2 sentences

2024Many of those courts “settled on some variation” of the three-factor test first formulated by the United States Supreme Court in Chevron Oil Co. v. Huson, 404 U.S. 97 , 106–07 (1971).

2024Many of those courts “settled on some variation” of the three-factor test first formulated by the United States Supreme Court in Chevron Oil Co. v. Huson, 404 U.S. 97 , 106–07 (1971).

22024–2024
Henry v. Goins green
tenn · 2003
1 sentence

2017Since 2003, when the Supreme Court adopted the three-factor test in Henry v. Goins, 104 S.W.3d at 481 , “Tennessee courts have wrestled with the apparent incompatibility of ‘excusable neglect’ and ‘willfulness.’” Pryor v. Rivergate Meadows Apartment Assocs.

12017–2017
In Re RES green
dc · 2009
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

12016–2016
In Re MF green
illappct · 2002
1 sentence

2016Factors to be considered are the parent‟s 2007); State v. Anonymous, 425 A.2d 939, 943 (Conn. 1979); In re R.E.S., 978 A.2d 182 , 189 (D.C. 2009); J.B. v. Fla. Dep’t of Children and Families, 170 So. 3d 780, 790 (Fla. 2015); In re A.R.A.S., 629 S.E.2d 822, 825 (Ga. Ct. App. 2006); In re RGB, 229 P.3d 1066, 1090 (Haw. 2010); In re M.F., 762 N.E.2d 701 , 709 (Ill.

12016–2016
Lassiter v. Department of Social Servs. of Durham Cty. green
scotus · 1981
1 sentence

2016In Lassiter , the United States Supreme Court identified a three-factor test for determining, on a case-by-case basis, whether the appointment of counsel is constitutionally required. 452 U.S. at 27-31, 101 S.Ct. 2153 .

12016–2016
Keck v. Nationwide Systems, Inc. green
tennctapp · 1973
2 sentences

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

2007Barbee, 689 S.W.2d at 866 (quoting the three-factor analysis from Davis v. Musler, 713 F.2d 907, 915 (2d Cir. 1983)). 2 Barbee, 689 S.W.2d at 865, 868 (defendant’s default not willful, although default was due to defense counsel’s failure to check his mail while out of the country); Evans v. Wintrow, No. M2003-00788-COA-R3-CV, 2005 WL 2416634 , at *5 (Tenn. Ct. App. Sept. 30, 2005) (plaintiff counsel’s failure to check his mail while out of state, which resulted in dismissal for failure to prosecute, was “sloppy and careless,” but not willful); see Campbell v. Archer, 555 S.W.2d 110, 111 , 112

12007–2007

Where else courts name it

TX 97 (1972–2026) AL 73 (1978–2024) PA 57 (1982–2024) ID 44 (1980–2024) MI 43 (1976–2025) CA 43 (1965–2025) CO 36 (1984–2026) NJ 32 (1990–2026) IL 29 (1988–2025) MN 28 (1981–2025) WA 26 (2001–2024) NV 22 (2006–2022) NM 21 (1987–2026) WI 20 (1995–2024) KS 20 (1983–2022) VI 16 (2014–2025) IN 16 (1984–2025) OH 15 (1999–2025) GA 15 (1996–2023) IA 14 (1984–2024) LA 14 (1994–2026) MS 14 (1994–2025) MO 14 (1985–2021) MD 12 (1988–2026) HI 12 (1978–2025) WV 12 (1988–2023) MT 11 (1998–2024) CT 11 (1985–2021) AZ 11 (1986–2022) NY 11 (1994–2026) NH 10 (1996–2023) DE 10 (2015–2025) OR 10 (1982–2025) NC 9 (2015–2025) AR 9 (2004–2024) UT 8 (2004–2022) MA 8 (2000–2025) TN 7 (1999–2024) FL 7 (2001–2026) VT 5 (2000–2025) ME 4 (1989–2020) VA 4 (2002–2025) SC 4 (2009–2023) NE 4 (1991–2016) WY 3 (1992–2026) KY 3 (2018–2024) SD 3 (1997–2024) DC 3 (1983–2021) ND 2 (2016–2022) OK 2 (1999–2010) AK 2 (1996–2025)

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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