Paul J. Frankenberg, III v. River City Resort, Inc.
Paul J. Frankenberg, III, a former corporate president and chief operating officer, sought a statutory lien on corporate property for alleged unpaid bonus and severance payments, citing Tennessee Code Annotated § 66-13-101. The Chancery Court dismissed his claim, determining that he did not qualify as an "employee" under the statute due to his managerial role, referencing the precedent set in State ex rel. McConnell v. People’s Bank & Trust Co. On appeal, the Court of Appeals affirmed the trial court's judgment. The appellate court reiterated that managing officers are excluded from the statutory definition of "employee" for the purpose of such liens, thus upholding the dismissal of Frankenberg's claim.