Baxter Bailey Investments LLC v. APL Limited Inc.
Plaintiffs, a debt collection company and a motor carrier, sued defendant APL Limited Inc. in general sessions court to collect unpaid transportation and delivery charges. Defendant moved for summary judgment and sanctions, arguing it was not the proper defendant. Plaintiffs voluntarily nonsuited, but the general sessions court awarded defendant attorney's fees as sanctions. The circuit court affirmed the award, albeit modifying the amount. On appeal, the Court of Appeals reversed, holding that the general sessions court lacked the statutory and inherent authority to impose attorney's fees as sanctions, noting that the Tennessee Rules of Civil Procedure (including Rule 11) do not apply to general sessions courts, and the Tennessee Consumer Protection Act was not properly raised.