Day on Torts
The Claims Commission had exclusive jurisdiction over a plaintiff’s tort and contract claims related to the State’s alleged mishandling of his charitable donation, so dismissal of the complaint filed in circuit court was affirmed.
In Blaylock v. University of Tennessee Martin, No. W2025-00212-COA-R3-CV (Tenn. Ct. App. May 13, 2026) (memorandum opinion), the plaintiff made a donation to the defendant university for a building project that was supposed to include inspirational plaques. Months after the project was completed, the plaintiff visited the area and saw that the plaques had been removed. The plaintiff filed this suit in circuit court alleging breach of contract and various tort claims, including defamation and negligent and intentional infliction of emotional distress. The University filed a motion to dismiss for lack of subject matter jurisdiction, asserting that the claims commission had exclusive jurisdiction of this claim against the State. The trial court granted the motion, and in this memorandum opinion, the Court of Appeals affirmed.
Tenn. Code Ann. § 9-8-307 removes immunity for specified claims against the State, and “expressly provides that the [Claims] Commission has exclusive jurisdiction to determine all monetary claims against the state based on the acts or omissions of state employees” falling within the listed categories. (internal citation and quotation omitted). Notably, “[o]utside of these categories, no jurisdiction exists for claims against the State.” (internal citation omitted).
The Court of Appeals rejected all of the plaintiff’s arguments that the circuit court retained jurisdiction over his claims against the State. In its analysis, the Court first pointed to the “exclusive jurisdiction” language of the statute cited above. In response to the plaintiff’s argument that other statutes required reversal of the dismissal, the Court explained that the “GTLA is inapplicable to claims asserted against the State.” The Court further explained that the statute discussing charitable gifts that the plaintiff sought to rely upon contained nothing explicitly stating that sovereign immunity was waived or that suit could be filed in the circuit court.
The Court of Appeals agreed with the trial court’s ruling that the plaintiff could not pursue his claims against the state in circuit court. It wrote that “to the extent that the State has waived sovereign immunity for any of the monetary claims asserted in the complaint under the Tennessee Claims Commission Act, the circuit court does not have subject matter jurisdiction to hear them because the Tennessee Claims Commission has exclusive subject matter jurisdiction.” Dismissal was thus affirmed.
This memorandum opinion was released eight months after oral arguments.