CINDA HADDON v. LADARIUS VANLIER, ET AL. - Articles

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CINDA HADDON v. LADARIUS VANLIER, ET AL.

Posted by: Azya Thornton on May 12, 2026

Court: TN Supreme Court

Attorneys 1: Michael A. Johnson, Nashville, TN, and Conor B. Dugan, Grand Rapids, MI, for the appellant, Auto-Owners Insurance Company.

Attorneys 2: Laura B. Baker and John A. Day, Brentwood, TN, for the appellee, Cinda Haddon.

Attorneys 3: C.E. Hunter Brush, James A. Beakes III, Allyson E. Lynch, and Corine A. Stark, Nashville, TN, for the amici curiae, American Property Casualty Insurance Association and National Association of Mutual Insurance Companies.

Attorneys 4: Michael R. Campbell, Douglas Campbell Jr., Chattanooga, TN, and Julie P. Bowling, Columbia, TN, for the amicus curiae, Tennessee Farmers Mutual Insurance Company.

Judge(s): WAGNER

In this case, we determine whether prejudgment interest may be awarded in an action brought against a tortfeasor and defended by an uninsured motorist carrier under Tennessee’s Uninsured Motorist Act. Tenn. Code Ann. §§ 56-7-1201–1206 (2016 & Supp. 2025). The trial court determined that Plaintiff Cinda Haddon could not recover prejudgment interest because her claim was for personal injury. The Court of Appeals reversed, finding that Ms. Haddon brought a contract action. Haddon v. V anlier, No. M2023-01151-COA-R3-CV , 2024 WL 4590434, at *2–3 (Tenn. Ct. App. Oct. 28, 2024), perm. app. granted, (Tenn. March 17, 2025). Accordingly, the Court of Appeals remanded this matter to the trial court for a determination of prejudgment interest. Id. at *5. Upon review, we find that this is a personal injury action. Because prejudgment interest is not available in a personal injury action, we reverse the Court of Appeals and reinstate the judgment of the trial court denying Ms. Haddon prejudgment interest.

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