ANDREW BETTIS AVIATION, LLC v. HOWARD WAYNE LANIER - Articles

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ANDREW BETTIS AVIATION, LLC v. HOWARD WAYNE LANIER

Posted by: Azya Thornton on May 29, 2026

Court: TN Court of Appeals

Attorneys 1: Matthew Wayne Willis and Grant T. Eison, Dyersburg, Tennessee, for the appellant, Howard Wayne Lanier.

Attorneys 2: William B. Ryan and Janelle Crandall Osowski, Memphis, Tennessee, for the appellee, Andrew Bettis Aviation, LLC.

Judge(s): MARONEY

This appeal presents two issues: (1) whether Appellant preserved his evidentiary issues concerning the trial court’s admission of video evidence in a jury trial, and (2) whether, following a bench trial, the trial court made sufficient findings under Rule 52.01 when rejecting Appellant’s COBRA claim. Because Appellant failed to include the evidentiary issues in a motion for new trial as required by Tennessee Rule of Appellate Procedure 3(e), and because Tennessee Rules of Appellate Procedure 13(b) and 36(b) are not applicable, we conclude that Appellant waived the evidentiary issues. Further, because the trial court’s order does not make sufficient findings, we cannot conduct a meaningful review of the COBRA issue, and we remand for compliance with Rule 52.01.

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