Baines v. Wilson County
Roy Baines, a former firefighter and ambulance driver, sued Wilson County, Wilson Emergency Management Agency (WEMA), and his supervisor, David Hale, for retaliatory discharge after being fired following a workers' compensation claim. The trial court dismissed the suit, ruling that Wilson County and WEMA were immune under the Tennessee Governmental Tort Liability Act (GTLA) and that Baines failed to establish a prima facie case against Hale because Hale was not his employer. The appellate court affirmed this decision, concurring that governmental entities are immune from common law retaliatory discharge claims under the GTLA, and that a supervisor cannot be held individually liable for retaliatory discharge unless they are the actual employer.