Reid Van Ness v. Tennessee Board of Funeral Directors and Embalmers, et al.

CourtDistrict Court, M.D. Tennessee
DecidedJune 3, 2026
Docket3:24-cv-01353
StatusUnknown

This text of Reid Van Ness v. Tennessee Board of Funeral Directors and Embalmers, et al. (Reid Van Ness v. Tennessee Board of Funeral Directors and Embalmers, et al.) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reid Van Ness v. Tennessee Board of Funeral Directors and Embalmers, et al., (M.D. Tenn. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

REID VAN NESS, ) ) Plaintiff, ) ) v. ) No. 3:24-cv-01353 ) TENNESSEE BOARD OF FUNERAL ) DIRECTORS AND EMBALMERS, et ) al., ) ) Defendants. )

MEMORANDUM OPINION The threshold standing issue has haunted this case at every turn. At the motion to dismiss stage, the Court accepted the Amended Complaint’s allegations as true and found that Van Ness alleged standing. (Doc. No. 62 at 15–25). On Van Ness’s motion for preliminary injunction, however, the Court found that the evidence contradicted his allegations and concluded that Van Ness was unlikely to succeed in establishing standing. (Doc. No. 87 at 11–20). The standing issue returns once again. This time it is the nail in the coffin. The injury that Van Ness claims to experience is not cognizable. Any act of forbearance he has taken—or will take—is what the law requires of him: that he refrain from crossing the line into unlicensed funeral directing. The Tennessee Board of Funeral Directors and Embalmers (together with all other named Defendants, “Board”), moreover, has never enforced the law against Van Ness for crossing that line. For those reasons, the Court will grant the Board’s motion for summary judgment (Doc. No. 109). I. FACTUAL BACKGROUND A. Procedural Background The Court must first address Van Ness’s untimely opposition. A brief recap of the timing of the events is in order. In March 2025, the Court set a jury trial on June 30, 2026, with dispositive motions due February 16, 2026, and pretrial filings due June 15, 2026. (Doc. No. 53 at 4; Doc. No. 54 at 1–2). The Board moved for summary judgment on February 16. (Doc. No. 109). Van Ness’s response was due twenty-eight days later on March 16. (Doc. No. 53 at 4). On March 9, counsel sought a “short” sixty-day extension, citing Van Ness’s “lack of

financial resources” and counsel’s “heavy trial schedule.” (Doc. No. 112 at 1–2). Counsel also mistakenly asserted that this case was “not yet set for trial” even though the trial date was set nearly a year prior. (Id. at 2). The Court denied the request because the extension would push the motion past the date by which it must be ripe under Local Rule 16.01(h)(i). (Doc. No. 114). Van Ness’s March 16 opposition deadline therefore remained in effect. Instead of filing an opposition by that deadline, counsel decided to do nothing. Having received no opposition, the Board moved to treat the motion as unopposed and its statement of facts as undisputed on March 26. (Doc. No. 115). Van Ness’s counsel filed a renewed extension request the same day. He complained that he “has practiced in state and federal court and has never had a timely request for an extension of time to file a response denied. Especially in a case

which is not yet set for trial.” (Doc. No. 116 at 1–2). The Court again denied the request. For the second time, the Court clarified what should have been apparent—that this case was, in fact, set for trial on June 30. (Doc. No. 118 at 1). Despite the Court’s denial of those extension requests, counsel ignored the Court, essentially granting himself the extension that he always wanted. On April 19—two days past the date corresponding to counsel’s originally requested sixty-day extension—counsel filed an opposition, response statement of facts, and motion to accept the late filings as timely. (Doc. Nos. 120, 121, 122). The Board opposed the retroactive extension request. (Doc. No. 123). Van Ness’s counsel has not shown good cause to excuse his neglect. Fed. R. Civ. P. 6(b)(1)(B). Counsel disregarded a deadline and ignored two orders explaining why the deadline stands. All attorneys learn—at the earliest stages of their career—that deadlines matter. The Federal Rules of Civil Procedure set deadlines that must be adhered to. As do the Local Rules.

And as does the Court. It should go without saying that counsel’s self-created busy litigation schedule is an insufficient excuse to blow Court-mandated deadlines. Father & Sons Lumber & Bldg. Supplies, Inc. v. NLRB, 931 F.2d 1093, 1096 (6th Cir. 1991) (finding that “heavy attorney workloads . . . do not constitute ‘good cause’” to excuse “a party’s failure to file a timely response”). That is especially so here, where the dispositive motion deadline and trial date were set nearly a year before Van Ness’s response was due. The deadline was not new or surprising. A party who chooses to sue must be prepared to litigate within the deadlines that bind every other party. That counsel “has never had a timely request for an extension of time to file a response denied” misses the point. It is not this Court’s role to manage counsel’s caseload so that counsel has time to defend the claims his client chose to bring.

This sideshow dispute has consumed five filings, two orders, and the Court’s time, all to address a deadline counsel had no authority to unilaterally extend. The Board’s motion is also before the Court without the benefit of a reply brief. Reopening briefing now would push it into the pretrial-filing window and derail the schedule the Court set nearly fifteen months ago. For those reasons, the motion to deem the motion for summary judgment as unopposed and the statement of material facts as undisputed (Doc. No. 115) will be granted, and the motion to accept the late filings as timely (Doc. No. 122) will be denied. The Court has nevertheless considered the untimely opposition and response statement of facts. Even with the benefit of counsel’s late submissions, they do not change the result. Van Ness lacks standing. B. Undisputed Facts In May 2025, the Court held an evidentiary hearing on Van Ness’s motion for a preliminary injunction. (Doc. No. 78 (“Inj. Hr’g Tr.”)). During that hearing the Court received testimony from Van Ness, the Board’s executive director Robert Gribble, and Aphton Wilson, whose grandfather’s funeral Van Ness performed in February 2025. The Court also received exhibits. As a result of

that proceeding, the Court made factual findings (Doc. No. 87 at 1–8). To be clear, the Court no longer acts as a factfinder at this posture. The Court instead draws facts from the hearing record only to the extent the Court finds them to be genuinely undisputed at summary judgment, and it draws all inferences in Van Ness’s favor.1

1 Local Rule 56.01(e) requires the nonmovant to respond to each asserted fact with an admission or denial. If a fact is disputed, the response must cite admissible evidence supporting the dispute, “limited to evidence specific to that particular fact.” Van Ness’s responses frequently exceed the scope of the Local Rule. Many purported denials do not actually dispute the fact asserted or the evidence cited by Defendants, but instead supply additional context or argument. (See, e.g., Doc. No. 120 (“Response SUMF”) ¶ 16 (denying that the Board did not approve the June 2022 letter by discussing the legal basis for the letter rather than addressing approval)). Several purported admissions likewise fail to respond to the fact asserted, instead admitting a different proposition altogether. (See, e.g., id. ¶ 14 (purporting to admit that the June 2022 letter “was sent on behalf of the Funeral Board” where the Board’s statement only asserted that Bryant sent the letter)). The most striking example appears in paragraph 33. There, Van Ness denies that the subject of the November 2023 meeting was Van Ness’s funeral directing activities. (Id. ¶ 33). He then purports to “admit” that “Bryant gave untrue, incomplete and misleading interpretations about Mr. Van Ness’ actions,” “failed to advise the Funeral Board that Mr. Van Ness was exempt from the regulatory scheme,” and “admitted he made no investigation into Mr.

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Bluebook (online)
Reid Van Ness v. Tennessee Board of Funeral Directors and Embalmers, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-van-ness-v-tennessee-board-of-funeral-directors-and-embalmers-et-al-tnmd-2026.