preemption inquiry (Tennessee) · Go Syfert
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preemption inquiry in Tennessee

45 Tennessee opinions name it 3 courts 1987–2022 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 (17)

CaseFollowedCited
Cipollone v. Liggett Group, Inc.green
scotus · 1992 · cited in 29 Tennessee opinions naming this issue, 2001–2006
2 sentences

2006Cipollone v. Liggett Group, Inc., 505 U.S. 504, 516 , 112 S. Ct. 2608, 2617 (1992); Riggs v. Burson, 941 S.W.2d 44, 48 (Tenn. 1997).

2006Cipollone v. Liggett Group, Inc., 505 U.S. 504, 516 , 112 S. Ct. 2608, 2617 (1992); Riggs v. Burson, 941 S.W.2d 44, 48 (Tenn. 1997).

2829
Riggs v. Bursongreen
tenn · 1997 · cited in 28 Tennessee opinions naming this issue, 2001–2006
2 sentences

2006Cipollone v. Liggett Group, Inc., 505 U.S. 504, 516 , 112 S. Ct. 2608, 2617 (1992); Riggs v. Burson, 941 S.W.2d 44, 48 (Tenn. 1997).

2006Cipollone v. Liggett Group, Inc., 505 U.S. 504, 516 , 112 S. Ct. 2608, 2617 (1992); Riggs v. Burson, 941 S.W.2d 44, 48 (Tenn. 1997).

2828
At&T Mobility LLC v. Concepciongreen
scotus · 2011 · cited in 2 Tennessee opinions naming this issue, 2015–2015
2 sentences

2015We must take care to consider the admonition in Concepcion that, under the doctrine of preemption, state courts cannot adopt “defenses that apply only to arbitration or that derive their meaning from the fact that an agreement to arbitrate is at issue.” Concepcion, 131 S. Ct. at 1746.

2015We must take care to consider the admonition in Concepcion that, under the doctrine of preemption, state courts cannot adopt “defenses that apply only to arbitration or that derive their meaning from the fact that an agreement to arbitrate is at issue.” Concepcion, 131 S.Ct. at 1746.

22
American Airlines, Inc. v. Wolensgreen
scotus · 1995 · cited in 2 Tennessee opinions naming this issue, 1996–2001
2 sentences

2001In Wolens, the Court concluded that plaintiff’s claims under the Consumer Fraud Act were preempted based on the “full text of the preemption clause, and of the ADA’s purpose to leave largely to the airlines themselves, and not at all to states, the selection and design of marketing mechanisms appropriate to the furnishing to the air transportation services.” 513 U.S. at 228 , 115 S.Ct. at 823 .

2001In Wolens, the Court concluded that plaintiff’s claims under the Consumer Fraud Act were preempted based on the “full text of the preemption clause, and of the ADA’s purpose to leave largely to the airlines themselves, and not at all to states, the selection and design of marketing mechanisms appropriate to the furnishing to the air transportation services.” 513 U.S. at 228 , 115 S.Ct. at 823 .

12
McHaffie Ex Rel. McHaffie v. Bunchgreen
mo · 1995 · cited in 1 Tennessee opinions naming this issue, 2016–2016
2 sentences

2016As the Missouri Supreme Court noted in McHaffie v. Bunch, 891 S.W.2d 822, 826 (Mo. 1995), “[t]he liability of the employer is fixed by the amount of the liability of the employee.” I disagree that adoption of the preemption rule runs afoul of Tennessee‟s comparative fault principles.

2016McHaffie, 891 S.W.2d at 826 ; Durben v. Am.

11
Lorio v. Cartwrightgreen
ilnd · 1991 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Lorio v. Cartwright, 768 F.Supp. 658, 660 (N.D.

11
McIntyre v. Balentinegreen
tenn · 1992 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016On the contrary, our supreme court, in McIntyre v. Balentine, directed that “[i]n all trials where the issue of comparative fault is before a jury, the trial court shall instruct the jury on the effect of the jury‟s finding as to the percentage of negligence as between the plaintiff or plaintiffs and the defendant or defendants.” McIntyre v. Balentine, 833 S.W.2d 52, 57 (Tenn. 1992); see also 8 Tenn. Prac.

11
Janet Harper v. Keith Churngreen
tennctapp · 2001 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016See Harper v. Churn, 83 S.W.3d 142, 146-48 (Tenn. Ct. App. 2002) (involving the assertion of a negligent entrustment claim and a vicarious liability claim at trial).

11
Clooney v. Geetinggreen
fladistctapp · 1977 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Although the preemption rule endeavors, in part, to guard juries from being prejudiced by evidence that could be used to support independent negligence claims against an employer, see, e.g., Clooney v. Geeting, 352 So. 2d 1216, 1220 (Fla. Dist.

11
Carroll v. Whitneygreen
tenn · 2000 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016If we adopted the preemption rule, we would effectively “force a jury to allocate fault between parties who were not wholly responsible.” Carroll v. Whitney, 29 S.W.3d 14, 19 (Tenn. 2000).

11
Schneidewind v. ANR Pipeline Co.green
scotus · 1988 · cited in 1 Tennessee opinions naming this issue, 2015–2015
2 sentences

2015To use the pertinent language from the preemption analysis, “the state law stands as an obstacle to the accomplishment and execution of the objectives of Congress.” Schneidewind, 485 U.S. at 300 , 108 S.Ct. 1145 (citations omitted).

2015To use the pertinent language from the preemption analysis, “the state law stands as an obstacle to the accomplishment and execution of the objectives of Congress.” Schneidewind, 485 U.S. at 300 , 108 S.Ct. 1145 (citations omitted).

11
Wyeth v. Levinegreen
scotus · 2009 · cited in 1 Tennessee opinions naming this issue, 2014–2014
1 sentence

2014Wyeth v. Levine, 555 U.S. 555, 565 (2009) (quoting Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996)).

11
Medtronic, Inc. v. Lohrgreen
scotus · 1996 · cited in 1 Tennessee opinions naming this issue, 2014–2014
1 sentence

2014Wyeth v. Levine, 555 U.S. 555, 565 (2009) (quoting Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996)).

11
Stanford v. Caesars Entertainment, Inc.green
tnwd · 2006 · cited in 1 Tennessee opinions naming this issue, 2014–2014
1 sentence

2014See Stanford v. Caesars Entm't, Inc., 430 F.Supp.2d 749 , 755 n. 4 (W.D.Tenn.2006). .

11
Joseph J. Waymire v. Norfolk and Western Railway Companygreen
ca7 · 2000 · cited in 1 Tennessee opinions naming this issue, 2009–2009
1 sentence

2009For example, in Waymire v. Norfolk & Western Railway Co., 218 F.3d 773, 774 (7th Cir. 2000), a train was involved in an accident with a truck at a railroad crossing.

11
Gustafson v. City Of Lake Angelusgreen
ca6 · 1996 · cited in 1 Tennessee opinions naming this issue, 1997–1997
1 sentence

1997See Gustafson, 76 F.3d at 791 ; Garden State Farms, 390 A.2d at 1180-1181 .

11
Wright v. County of Winnebagogreen
illappct · 1979 · cited in 1 Tennessee opinions naming this issue, 1997–1997
2 sentences

1997Second, although the preemption analysis may have differed if the statute eliminated an existing use based solely on aircraft noise, see Wright v. County of Winnebago, 73 Ill.App.3d 337 , 29 Ill.Dec. 347 , 391 N.E.2d 772, 777 (1979), the law, as we have discussed, is related to numerous legislative interests.

1997Second, although the preemption analysis may have differed if the statute eliminated an existing use based solely on aircraft noise, see Wright v. County of Winnebago, 73 Ill.App.3d 337 , 29 Ill.Dec. 347 , 391 N.E.2d 772, 777 (1979), the law, as we have discussed, is related to numerous legislative interests.

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
Louisiana Pub. Serv. Comm'n v. FCC green
scotus · 1986
2 sentences

1987The power given to Congress by Article VI of the Constitution results in the so-called preemption doctrine: “The supremacy clause of Article VI of the Constitution provides Congress with the power to preempt state laws.” Louisiana Public Service Commission v. Federal Communications Commission, 476 U.S. 335 , 106 S.Ct. 1890, 1898 , 90 L.Ed.2d 369 (1986).

1987The power given to Congress by Article VI of the Constitution results in the so-called preemption doctrine: “The supremacy clause of Article VI of the Constitution provides Congress with the power to preempt state laws.” Louisiana Public Service Commission v. Federal Communications Commission, 476 U.S. 335 , 106 S.Ct. 1890, 1898 , 90 L.Ed.2d 369 (1986).

21987–1987
Wells v. Chattanooga Bakery, Inc. green
tennctapp · 2014
1 sentence

2022Id. at 393 .

12022–2022
Jeld-Wen, Inc. v. Superior Court green
calctapp · 2005
2 sentences

2016The California Supreme Court, in adopting the preemption rule, described the nexus that exists between an employer‟s negligent entrustment or negligent hiring and its employee‟s own negligence: No matter how negligent an employer was in entrusting a vehicle to an employee, however, it is only if the employee then drove negligently that the employer can be liable for negligent entrustment, hiring, or retention. [Jeld-Wen, Inc. v. Superior Court (2005), 131 Cal.App.4th 853, 863-864 , 32 Cal.Rptr.3d 351 ].

2016The California Supreme Court, in adopting the preemption rule, described the nexus that exists between an employer‟s negligent entrustment or negligent hiring and its employee‟s own negligence: No matter how negligent an employer was in entrusting a vehicle to an employee, however, it is only if the employee then drove negligently that the employer can be liable for negligent entrustment, hiring, or retention. [Jeld-Wen, Inc. v. Superior Court (2005), 131 Cal.App.4th 853, 863-864 , 32 Cal.Rptr.3d 351 ].

12016–2016
Geier v. American Honda Motor Co. green
scotus · 2000
2 sentences

2013It thereby would have presented an obstacle to the variety and mix of devices that the federal regulation sought.” Id. at 881 , 120 S.Ct. 1913 .

2013It thereby would have presented an obstacle to the variety and mix of devices that the federal regulation sought.” Id. at 881 , 120 S.Ct. 1913 .

12013–2013
Morales v. Trans World Airlines, Inc. green
scotus · 1992
2 sentences

2001The argument that the savings clause in the prior statute limited the scope of the preemption clause was rejected by the Court stating that “[a] general ‘remedies’ saving clause cannot be allowed to supersede the specific substantive pre-emption provision...” Id. at 385 , 112 S.Ct. at 2037 .

2001The argument that the savings clause in the prior statute limited the scope of the preemption clause was rejected by the Court stating that “[a] general ‘remedies’ saving clause cannot be allowed to supersede the specific substantive pre-emption provision...” Id. at 385 , 112 S.Ct. at 2037 .

12001–2001
Garden State Farms, Inc. v. Mayor Louis Bay, II green
nj · 1978
1 sentence

1997See Gustafson, 76 F.3d at 791 ; Garden State Farms, 390 A.2d at 1180-1181 .

11997–1997

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 29-14-101 (26) TN § Tenn. Code Ann. § 29-14-102 (26) TN § Tenn. Code Ann. § 29-14-110 (26) TN § Tenn. Code Ann. § 29-14-113 (26) TN § Tenn. Code Ann. § 29-16-102 (26) TN § Tenn. Code Ann. § 29-16-104 (26) TN § Tenn. Code Ann. § 29-16-107 (26) TN § Tenn. Code Ann. § 29-16-114 (26) TN § Tenn. Code Ann. § 29-16-122 (26) TN § Tenn. Code Ann. § 29-16-126 (26) TN § Tenn. Code Ann. § 42-3-101 (26) TN § Tenn. Code Ann. § 65-6-109 (26)

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 277 (1911–2026) NY 112 (1981–2026) IL 101 (1974–2026) TX 93 (1969–2025) NJ 69 (1971–2026) PA 66 (1966–2025) OH 50 (1975–2026) MN 45 (1984–2019) TN 45 (1987–2022) IN 38 (1981–2024) MI 35 (1970–2025) CO 32 (1972–2025) WA 32 (1972–2021) NM 31 (1987–2019) WI 31 (1980–2025) AZ 30 (1971–2025) IA 30 (1978–2026) MD 29 (1977–2026) MA 27 (1964–2023) FL 24 (1962–2021) LA 23 (1962–2024) OK 20 (1986–2024) GA 19 (1991–2022) MO 19 (1971–2017) AL 17 (1964–2014) MT 16 (1977–2025) KS 16 (1922–2026) OR 14 (1985–2023) NV 14 (2000–2026) SC 13 (1984–2019) NC 13 (1973–2026) NH 13 (1995–2019) CT 12 (1990–2024) HI 12 (1982–2023) UT 11 (1992–2012) NE 10 (1982–2006) KY 10 (1979–2026) MS 9 (1968–2013) ID 9 (1979–2018) AK 8 (1967–2022) DE 8 (1980–2025) WV 7 (2009–2024) VT 7 (1988–2024) RI 7 (1985–2020) ME 6 (1989–2025) AR 5 (1984–2025) ND 5 (1991–2025) VA 5 (1985–2021) VI 4 (2010–2026) SD 4 (1977–2020) DC 3 (1986–2009) WY 2 (2014–2014) PR 2 (2023–2025)

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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