State of Tennessee v. Wanda Dean Wallace
The State of Tennessee appealed the assessment of discretionary costs in an eminent domain action against property owner Wanda Dean Wallace. The Circuit Court had awarded Wallace discretionary costs after a jury found her entitled to damages exceeding the State's initial tender. The State argued its exemption from such costs in eminent domain cases. The Court of Appeals agreed, concluding that a 1994 amendment to Tennessee Code Annotated § 29-17-812 removed the express statutory authority to assess discretionary costs against the State. Consequently, the appellate court reversed the Circuit Court's judgment and vacated the $5,650 award of discretionary costs against the State.