Overnite Transportation Co. v. Teamsters Local Union No. 480
The Tennessee Supreme Court reviewed an appeal concerning civil contempt. Overnite Transportation Company had sought civil contempt against Teamsters Local Union No. 480 and its officers for violating court orders during a strike. The trial court dismissed Overnite's petition, ruling that compensatory damages for civil contempt were not available if the contemptuous conduct had ceased before the hearing. The Court of Appeals reversed this decision. The Supreme Court affirmed the Court of Appeals' judgment, holding that an order declining to hold a party in civil contempt is appealable and that compensatory damages under Tennessee Code Annotated section 29-9-105 are available for forbidden acts, even if the conduct is no longer ongoing. The case was remanded to the trial court for further proceedings consistent with this opinion.