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Plaintiff Nancy Jenkins sought to recover a judgment from Loudon County against a deputy sheriff, Voyd Carruth, for civil rights violations under 42 U.S.C. § 1983. The trial court and Court of Appeals dismissed her suit, reasoning that the Tennessee Governmental Tort Liability Act (GTLA), T.C.A. §§ 29-20-101, et seq., implicitly repealed T.C.A. §§ 8-8-301 through 8-8-303, which provide a waiver of immunity for counties regarding deputy misconduct. The Supreme Court of Tennessee reversed this decision, holding that the GTLA does not supersede the specific provisions of T.C.A. §§ 8-8-301, et seq., for the non-negligent misconduct of sheriff's deputies. The Court found no irreconcilable conflict, emphasizing that the special statute for deputy misconduct remedies remains viable. The case was remanded for further proceedings, allowing Loudon County to litigate liability and damages.
Jenkins v. Loudon County is a workers' compensation case decided in Tennessee Supreme Court. This case addresses legal issues related to compensation claims, benefits, and court rulings.
It is commonly referenced in legal research involving workers' compensation laws in Tennessee Supreme Court.
Full Decision Text1 Pages
Plaintiff Nancy Jenkins sought to recover a judgment from Loudon County against a deputy sheriff, Voyd Carruth, for civil rights violations under 42 U.S.C. § 1983. The trial court and Court of Appeals dismissed her suit, reasoning that the Tennessee Governmental Tort Liability Act (GTLA), T.C.A. §§ 29-20-101, et seq., implicitly repealed T.C.A. §§ 8-8-301 through 8-8-303, which provide a waiver of immunity for counties regarding deputy misconduct. The Supreme Court of Tennessee reversed this decision, holding that the GTLA does not supersede the specific provisions of T.C.A. §§ 8-8-301, et seq., for the non-negligent misconduct of sheriff's deputies. The Court found no irreconcilable conflict, emphasizing that the special statute for deputy misconduct remedies remains viable. The case was remanded for further proceedings, allowing Loudon County to litigate liability and damages.
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