TBA Law Blog


Posted by: Stacey Shrader Joslin on May 22, 2023

In an opinion released last week, the Tennessee Supreme Court unanimously held that a trial court's voluntary dismissal order in a governmental tort liability action could not be altered or amended because the plaintiff’s amended complaint rendered it of no legal effect. The decision came in the case of George Gary Ingram, who filed a lawsuit against a physician, a hospital and two other defendants after suffering complications following a medical procedure. Ingram later filed an amended complaint that named only the physician as a defendant. The physician argued the lawsuit should be dismissed under the Governmental Tort Liability Act because the hospital, which was his employer and a governmental entity, was required to be named a party to the suit. Read more from the AOC.