JEFF HURST v. CITY OF MORRISTOWN

CourtCourt of Appeals of Tennessee
DecidedJuly 8, 2025
DocketE2024-00779-COA-R3-CV
StatusPublished

This text of JEFF HURST v. CITY OF MORRISTOWN (JEFF HURST v. CITY OF MORRISTOWN) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JEFF HURST v. CITY OF MORRISTOWN, (Tenn. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE April 15, 2025 Session

JEFF HURST v. CITY OF MORRISTOWN

Appeal from the Circuit Court for Hamblen County No. 21CV047 William Erwin Phillips, II, Judge ___________________________________

No. E2024-00779-COA-R3-CV ___________________________________

This is a Governmental Tort Liability Act (“GTLA”) case, Tennessee Code Annotated section 29-20-101, et seq., alleging negligent operation of a street sweeper by a city employee. The trial court denied the city’s claims of immunity and entered judgment after a nonjury trial, apportioning 51 percent fault to the city’s employee who was driving the street sweeper and 49 percent fault to the driver of the pickup truck that was involved in a collision with the sweeper. The city appealed. We affirm.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Circuit Court Affirmed; Case Remanded

JOHN W. MCCLARTY, J., delivered the opinion of the court, in which D. MICHAEL SWINEY, C.J., and KRISTI M. DAVIS, J., joined.

Benjamin K. Lauderback, Knoxville, Tennessee, for the appellant, City of Morristown.

W. Lewis Jenkins, Jr., Dyersburg, Tennessee, and F. Braxton Terry, T. Dillon Parker, and Gabriel C. Stapleton, Morristown, Tennessee, for the appellee, Jeff Hurst.

OPINION

I. BACKGROUND

Around 10:00 a.m. on March 8, 2021, on four-lane East Morris Boulevard (“Highway”) in Morristown, Tennessee (“City”), Jeff Kimbrough (“Employee”), was operating a street sweeper (“Sweeper”) going about five to eight miles per hour (“mph”). It was the first time the road in question had been swept in 2021. According to Employee, before he began work that morning he reviewed, cleaned, and confirmed the Sweeper’s light systems were working. Employee noted that no less than twelve of the lights on the back of the Sweeper were turned on, including two flashing lights on each of the upper corners, a strobe light, a LED light bar, two flashing lights on the lower rear bumper, and two white lights mounted along the bumper. Employee, who had operated the Sweeper for the City since 2001, had never before been involved in any accident.

As Employee was moving along the Highway during this same time period, Charles Hurst (“Driver”), 87 years old, suddenly crashed his 2001 Chevrolet S-10 truck into the rear of the Sweeper. Driver was traveling at approximately 40 mph, the posted speed limit. No skid marks were left by the truck. Driver suffered a right open femur fracture, as well as other injuries (broken in multiple segments and moved two or three widths from itself), right L1 and bilateral L2 transverse process fractures, a broken rib, a separated rib, and abdominal bleeding. Driver later passed away when he could not overcome the injuries he sustained in the crash.

Upon Driver’s son arriving on the scene shortly after the accident, Driver declared: “I don’t know what happened, I hit something, but I never saw a thing. I never saw one thing.” Driver was transported by ambulance from the site of the accident to the Emergency Department at Morristown Hamblen Hospital. There, Driver informed the investigating officer:

I didn’t know I hit it ‘til I’d done hit it. I didn’t see it, I just didn’t see it. I don’t know. I can’t figure out why I didn’t see him. I hit him and I saw the windshield broke. I didn’t know what I hit to tell you the truth.

Driver was transferred to the University of Tennessee (“UT”) Medical Center in Knoxville that same evening because he had “poly trauma” that required a higher level of care. Dr. Kostas Triantafillou, an orthopedic surgeon noted:

[A]ny time bone comes out through the skin, skin is - or bone is a living tissue. It’s like a tree, it needs roots to survive, so the more the bone comes out through the skin, the more you’re pulling the tree out from its roots and the higher the chance that tree will die.

****

In this case, he had a high grade injury because for the thigh bone to come out through the, the skin, it has to travel a huge distance to get out through that skin as opposed, to breaking your shin bone, which is right underneath the skin and the thigh bone, . . . so even when we repair them, we know a portion of bone can die and get infected . . . if it doesn’t have blood flow. . . . So, this is a high grade injury because it’s a broken thigh bone coming out through the skin and, that alerts us and in future treatment plans that if something’s not quite going right to have a high suspicion that something -2- could be complicated with an infection, for example.

This lawsuit was initially filed by Driver on May 14, 2021. Driver’s son, Jeff Hurst (“Son”), became the party plaintiff upon Driver’s death.1 Son asserts in this action that the City was negligent for the following reasons: (1) Employee failed to activate the water jets or spray bars on the Sweeper, which would have prevented the Sweeper from becoming obscured to approaching motorists; (2) the Sweeper was not equipped with appropriate lighting to warn approaching motorists of the Sweeper’s presence and slow speed, as required by the Manual on Uniform Traffic Control Devices (“MUTCD”) and Tennessee Code Annotated section 55-8-190;2 and (3) the Sweeper was operating at a slow speed that violated Tennessee Code Annotated section 55-8-1543 and created a hazardous condition.

At trial, Son’s expert testified that a sweeper creates dust because it pushes air onto the road surface at “about 250 miles an hour,” which agitates the dirt and grime on the road. The expert related that it is well known in the street sweeping industry that dust “can obscure the sweeper.” Employee himself stated immediately after the crash to an investigating officer and a supervisor that Driver possibly had difficulty in seeing the Sweeper because it had been “kicking up” a lot of dust. 4 The Sweeper in this case had seven spray bars mounted under the front bumper with jet nozzles to spray water on the surface of the street to help prevent dust from “getting airborne” and to reduce the amount of dust created by the operation of the Sweeper. In this case, however, Employee had not engaged the spray bars.

A focus at trial was the MUTCD, which provides, in pertinent part, as follows:

Mobile operations shall have appropriate devices on the equipment (that is,

1 On September 28, 2021, a “Suggestion of Death” was filed for Driver that indicated he passed away on September 22, 2021. A subsequent agreed order was entered on October 12, 2021 that allowed for the substitution of Son as the plaintiff. 2 Section 55-8-190(c) provides as follows:

(c) Absent noncompliance with this section, operator negligence or an intentional tort by an operator, operations of a street sweeper in compliance with this section shall not be a violation of law, and shall not subject the street sweeper to liability for claims for personal injury, property damage or death. 3 Section 55-8-154. Minimum speed limits. (a) No person shall drive a motor vehicle at such a slow speed as to impede the normal and reasonable movement of traffic, except when reduced speed is necessary for safe operation or in compliance with law. 4 A video excerpt of body camera footage from the scene of the crash captured Employee talking about the dust created by the Sweeper on the day of the incident and was key evidence underlying the trial court’s finding that Employee lacked credibility on this point. -3- high-intensity rotating, flashing, oscillating, or strobe lights, signs, or special lighting), or shall use a separate vehicle with appropriate warning devices.

Based upon their arguments at trial, all parties accepted that street sweeping is a “mobile” operation for the purpose of the MUTCD. The evidence revealed that the Sweeper was not equipped with “high intensity” lighting.

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Bluebook (online)
JEFF HURST v. CITY OF MORRISTOWN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeff-hurst-v-city-of-morristown-tennctapp-2025.