The Tennessee Supreme Court this week ruled that a trial court must consider both the legal basis and the injuries for which damages are sought when determining the applicable statute of limitations for each claim in a lawsuit.
Statutes of limitations exist in both criminal and civil law and limit the time for filing legal actions. Civil lawsuits may involve multiple claims and differing legal theories. Different statutes of limitations may apply to the claims.
The case involves a dispute over contractual conditions related to the sale of property in Rutherford County. Brenda Benz-Elliott entered into an agreement with Barrett Enterprises and Ronnie Barrett to sell a portion of her 91 acres along I-24. The contract included conditions that Elliott would retain a 60-foot strip of land to allow for an extension of a road to connect her property. When the sale of the property closed, the deed did not include the 60-foot reservation of land for Elliott.
Elliott sued the defendants and asserted multiple legal claims, including breach of contract. She sought money damages and specific performance, which is an order from the court requiring a party to perform a specific act, in this case, to restore the 60-foot land reservation.
The trial court found in favor of Elliott for her breach of contract claim and awarded her $650,000 in damages, but did not order any specific performance. The defendants appealed, asserting, among other things, that the three-year statute of limitations for injuries to real property barred her claim. The Court of Appeals agreed and reversed the decision of the trial court.
The Tennessee Supreme Court granted Elliott’s application to appeal to determine which statute of limitations applies to her breach of contract claim – three years for injury to real property or six years for a contract action.
The Court said it is necessary to conduct a fact-intensive analysis of the core of each claim to determine both the basis of the claim and the type of injuries for which damages are sought. Elliott’s claim of a decrease in the value of her property stemmed from her breach of contract claim. In addition the specific performance remedy she sought is exclusively a remedy of contract claims. Based on this, the Court ruled that her lawsuit was timely under the six-year statute of limitations for contract actions and sent the case back to the Court of Appeals for further consideration.
To read the unanimous opinion in Brenda Benz-Elliott v. Barrett Enterprises, LP et al., authored by Justice Cornelia A. Clark, visit the Opinions section of TNCourts.gov.
Source: Tennessee Supreme Court