Wilma Griffin v. Campbell Clinic, P.A.

The plaintiff filed a civil action in the general sessions court asserting a health care liability claim against the defendant. Following a trial, the general sessions court entered judgment in the defendant’s favor. The next day, the plaintiff filed a notice of appeal and deposited $211.50 with the general sessions court clerk, which represents the amount of the standard court cost of $150 for an appeal to the circuit court required by Tennessee Code Annotated section 8-21-401(b)(1)(C)(i) plus state and local litigation taxes. The circuit court dismissed the plaintiff’s appeal, concluding that it lacked subject matter jurisdiction because the plaintiff failed to file a bond “with good security . . . for the costs of the appeal” under Tennessee Code Annotated section 27-5-103. The Court of Appeals reversed the trial court’s judgment, concluding that payment of the standard court cost is sufficient to perfect an appeal from the general sessions court to the circuit court. After a thorough review of the statutory scheme at issue, we conclude that the plaintiff’s cash bond was sufficient to perfect her appeal to the circuit court. We therefore affirm the judgment of the Court of Appeals and remand this case to the trial court for further proceedings.