The Court of Appeals of Tennessee has affirmed a summary judgment in the case of Tray Simmons v. Dr. Shahidul Islam, et al., which involved a healthcare liability claim against the deceased psychiatrist and his clinic. The ruling, issued on May 21, 2026, means that Simmons will not receive damages for his claims, as the court found he failed to provide adequate expert testimony to support his case.
This decision is significant for Simmons, who had argued that the psychiatrist's actions caused him harm. The ruling also raises questions about how cases are handled when a party dies during litigation, especially regarding the requirement for substitution of parties.
Background
Tray Simmons filed a lawsuit in 2015 against Dr. Shahidul Islam and the Anxiety Depression Disorders Clinic, alleging that he suffered injuries due to the psychiatrist's breach of the standard of care. After a lengthy discovery process, Dr. Islam and the Clinic sought summary judgment, claiming Simmons could not prove damages without expert testimony.
The key evidence in the case came from Dr. Sherri Studstill, who was hired as an expert witness by Simmons. However, her statements were contradictory. In an affidavit, she claimed that Simmons suffered injury due to Dr. Islam's breach of care, but during her deposition, she stated that damages were only “possible.” This inconsistency led the trial court to grant summary judgment in favor of Dr. Islam and the Clinic.
After the trial court's ruling, Simmons appealed. The Court of Appeals heard the case in July 2024 and issued its ruling in December 2024, affirming the lower court's decision. However, during the appellate process, Dr. Islam passed away on August 12, 2024. Simmons became aware of the psychiatrist's death only after the Tennessee Supreme Court denied his application for permission to appeal in April 2025.
The Ruling
The Court of Appeals, led by Judge Jeffrey Usman, ruled that the trial court did not err in granting summary judgment. The court stated, "The contradictory sworn statements provided by Dr. Studstill cancelled one another out, leaving the plaintiff with no expert testimony establishing damages." This ruling confirmed that without sufficient expert testimony, Simmons could not prove his claims against Dr. Islam.
Following the ruling, Simmons filed multiple motions in the trial court, seeking relief based on Dr. Islam's death and alleged misconduct by the defense attorneys for not disclosing the psychiatrist's death during the appeal. However, the trial court denied these motions, stating that the death of Dr. Islam was irrelevant to the proceedings.
Impact
The decision in this case underscores the importance of expert testimony in healthcare liability claims. It also highlights the procedural complexities that arise when a party dies during litigation. The court's ruling clarifies that the failure to substitute a party after death does not automatically void previous judgments, as long as the deceased party was alive during the critical stages of the case.
This ruling may have broader implications for similar cases in Tennessee, as it establishes that courts can continue to operate even when a party dies, provided that proper procedures are followed. It also emphasizes the need for parties to be diligent in ensuring that all procedural requirements are met, particularly in cases involving expert witnesses.
What's Next
Simmons may seek to appeal the decision to the Tennessee Supreme Court, but it is unclear whether he will succeed in doing so. There are no related cases pending that directly affect this ruling. The court's affirmation of the summary judgment effectively ends Simmons's pursuit of damages in this matter.