KNOX COUNTY TENNESSEE v. DELINQUENT TAXPAYERS

Court of Appeals of Tennessee·Decided July 7, 2026·No. E2026-00812-COA-T10B-CV·Published·Judge Thomas R. Frierson, II

Opinion

07/07/2026 IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE Assigned on Briefs May 28, 2026

KNOX COUNTY TENNESSEE ET AL. v. DELINQUENT TAXPAYERS ET AL.

Appeal from the Chancery Court for Knox County No. 201957-2 Christopher D. Heagerty, Jr., Chancellor

No. E2026-00812-COA-T10B-CV

This is a recusal appeal filed by the pro se petitioner relative to the underlying delinquent taxpayer action. Because the petitioner has not demonstrated a factual basis warranting recusal, we affirm the judgment of the trial court denying the motion to recuse.

Tenn. Sup. Ct. R. 10B Interlocutory Appeal as of Right;

Judgment of the Chancery Court Affirmed; Case Remanded

THOMAS R. FRIERSON, II, J., delivered the opinion of the court, in which W. NEAL MCBRAYER and VALERIE L. SMITH, JJ., joined.

Douglas Vernon, Powell, Tennessee, Pro Se.1

OPINION

I. Factual and Procedural Background

This case arises from a complaint filed by Knox County, Tennessee (“Knox County”), against Douglas Vernon (“Petitioner”), seeking judicial sale of Petitioner’s real property located on Irwin Road in Powell, Tennessee (“the Property”), due to Petitioner’s failure to pay real property taxes. Following protracted litigation spanning nearly four years, the Knox County Chancery Court (“trial court”) entered a memorandum opinion and order on August 6, 2025, directing that the Property be sold pursuant to applicable statutory law regarding delinquent real property taxes. Petitioner subsequently filed a motion to alter

1 Knox County did not file a brief or otherwise appear in this appeal.

or amend the order, which the trial court denied in a written order entered on October 2, 2025. Accordingly, the Property was sold at public sale, the report for which was filed on October 23, 2025.

On October 24, 2025, Petitioner filed a motion for stay of execution of both the August 5, 2025 and October 2, 2025 orders. However, before Petitioner’s motion for stay could be resolved, Petitioner filed a motion to recuse the chancellor on October 31, 2025, claiming that the chancellor had shown “prejudice” against Petitioner throughout the litigation. Before the trial court ruled on either motion, Petitioner filed a notice of appeal, pursuant to Tennessee Rule of Appellate Procedure 3, in this Court on November 3, 2025. On November 17, 2025, the trial court entered a memorandum opinion and order determining that because Petitioner had filed a notice of appeal to this Court, the trial court no longer maintained jurisdiction to rule on Petitioner’s motions for stay and recusal.

On March 2, 2026, this Court entered an order in Petitioner’s Rule 3 appeal, which had been docketed as No. E2025-01721-COA-R3-CV, remanding the case to the trial court for consideration of Petitioner’s motions for stay and for recusal. Accordingly, the trial court entered a detailed memorandum opinion on May 5, 2026, addressing each point in Petitioner’s motion to recuse and ultimately denying the motion. Petitioner timely appealed the trial court’s order denying recusal.

II. Standard of Review

We recognize that Petitioner is a pro se litigant and respect his decision to proceed self-represented. Regarding self-represented litigants, this Court has explained:

Pro se litigants who invoke the complex and sometimes technical procedures of the courts assume a very heavy burden. Conducting a trial with a pro se litigant who is unschooled in the intricacies of evidence and trial practice can be difficult. Nonetheless, trial courts are expected to appreciate and be understanding of the difficulties encountered by a party who is embarking into the maze of the judicial process with no experience or formal training.

Irvin v. City of Clarksville, 767 S.W.2d 649, 652 (Tenn. Ct. App. 1988) (internal citations omitted). Parties proceeding without benefit of counsel are “entitled to fair and equal treatment by the courts,” but we “must not excuse pro se litigants from complying with the same substantive and procedural rules that represented parties are expected to observe.” Hessmer v. Hessmer, 138 S.W.3d 901, 903 (Tenn. Ct. App. 2003). This Court must “be mindful of the boundary between fairness to a pro se litigant and unfairness to the pro se litigant’s adversary.” Id. Furthermore, “[p]ro se litigants are not . . . entitled to shift the burden of litigating their case to the courts.” See Chiozza v. Chiozza, 315 S.W.3d 482, 487 (Tenn. Ct. App. 2009) (quoting Whitaker v. Whirlpool Corp., 32 S.W.3d 222, 227 (Tenn.

Ct. App. 2000)).

With respect to recusal motions filed pursuant to Tennessee Supreme Court Rule 10B, our Supreme Court has instructed:

“Tennessee litigants are entitled to have cases resolved by fair and impartial judges.” Cook v. State, 606 S.W.3d 247, 253 (Tenn. 2020) (citing Davis [v. Liberty Mut. Ins. Co.], 38 S.W.3d [560,] 564 [(Tenn. 2001)]); see also State v. Griffin, 610 S.W.3d 752, 757-58 (Tenn. 2020). To preserve public confidence in judicial neutrality, judges must be fair and impartial, both in fact and in perception. Cook, 606 S.W.3d at 253; Kinard v. Kinard, 986 S.W.2d 220, 228 (Tenn. Ct. App. 1998). To these ends, the Tennessee Rules of Judicial Conduct (“RJC”) declare that judges must “act at all times in a manner that promotes public confidence in the independence, integrity, and impartiality of the judiciary, and shall avoid impropriety and the appearance of impropriety.” Tenn. Sup. Ct. R. 10, RJC 1.2. Another provision declares that judges “shall uphold and apply the law, and shall perform all duties of judicial office fairly and impartially.” Id., RJC 2.2.

To act “impartially” is to act in “absence of bias or prejudice in favor of, or against, particular parties or classes of parties, as well as maintenance of an open mind in considering issues that may come before a judge.” Id., Terminology. “A judge shall disqualify himself or herself in any proceeding in which the judge’s impartiality might reasonably be questioned.” Id., RJC 2.11(A).

Rule of Judicial Conduct 2.11 “incorporates the objective standard Tennessee judges have long used to evaluate recusal motions.” Cook, 606 S.W.3d at 255. “Under this objective test, recusal is required if ‘a person of ordinary prudence in the judge’s position, knowing all of the facts known to the judge, would find a reasonable basis for questioning the judge’s impartiality.’” Id. (quoting Davis, 38 S.W.3d at 564-65).

The intermediate appellate courts have explained that the proponent of a recusal motion bears the burden of establishing that recusal is appropriate and that any alleged acts of bias or prejudice arise from extrajudicial sources rather than from events or observations during the litigation of the case. Tarver v. Tarver, No. W2022-00343-COA-T10B-CV, 2022 WL 1115016, at *2 (Tenn. Ct. App. Apr. 14, 2022). A trial judge has a duty to serve unless the proponent establishes a factual basis warranting recusal. Raccoon Mtn. Caverns and Campground, LLC v. Nelson, No. E2022-00989-COA-T10B-CV, 2022 WL 3100606, at *3 (Tenn. Ct. App. Aug. 4, 2022) (quoting Rose v. Cookeville Reg’l Med. Ctr., No. M2007-

02368-COA-R3-CV, 2008 WL 2078056, at *2 (Tenn. Ct. App. May 14, 2008)).

Adams v. Dunavant, 674 S.W.3d 871, 878-79 (Tenn. 2023). “To disqualify [a trial judge], prejudice must be of a personal character, directed at the litigant, must stem from an extrajudicial source and result in an opinion on the merits on some basis other than what the judge learned from . . . participation in the case.” Alley v. State, 882 S.W. 2d 810, 821 (Tenn. Crim. App. 1994) (internal quotation marks and citations omitted).

Tennessee Supreme Court Rule 10B also governs appeals from orders denying a motion to recuse. The standard of review respecting such orders is de novo with no presumption of correctness. See Tenn. Sup. Ct. R. 10B, § 2.01. Regarding the scope of review in a Rule 10B appeal, this Court has explained:

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KNOX COUNTY TENNESSEE v. DELINQUENT TAXPAYERS, (Tenn. Ct. App. 2026).

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