The Tennessee Supreme Court ruled on May 12, 2026, that Cinda Haddon is not entitled to prejudgment interest in her personal injury case against Ladarius Vanlier. The decision affects how prejudgment interest is awarded in similar cases involving uninsured motorist claims in Tennessee.

The ruling clarifies the legal distinction between personal injury claims and contract claims under Tennessee’s Uninsured Motorist Act. This case is significant because it sets a precedent regarding the availability of prejudgment interest in personal injury lawsuits, which could impact future cases involving uninsured motorists.

Background

Cinda Haddon was involved in a car accident with Ladarius Vanlier, who was uninsured. Following the accident, Haddon sued Vanlier for negligence, seeking compensation for her injuries. Because Vanlier could not be served with legal papers, Haddon proceeded against her uninsured motorist carrier, Auto-Owners Insurance Company, under Tennessee’s Uninsured Motorist Act.

The trial court found that Vanlier was at fault and that Auto-Owners had a valid uninsured motorist policy covering Haddon. After a jury trial, Haddon was awarded $320,000 in damages for her injuries. However, when Haddon sought prejudgment interest on this amount, the trial court denied her request, stating that her claim was for personal injury, which does not qualify for prejudgment interest under Tennessee law.

Haddon appealed the trial court's decision. The Court of Appeals reversed the trial court's ruling, stating that Haddon’s claim was based on a contract with Auto-Owners, which would allow for prejudgment interest. This led to the Tennessee Supreme Court taking up the case to clarify the legal basis for awarding prejudgment interest in such cases.

The Ruling

The Tennessee Supreme Court, led by Justice Mary L. Wagner, ruled that Haddon’s claim was indeed a personal injury action and not a contract claim. The court emphasized that prejudgment interest is not available in personal injury cases under Tennessee law. The court stated, “Because the gravamen of Ms. Haddon’s action is for personal injury, she is not entitled to prejudgment interest.”

The court reversed the Court of Appeals' decision and reinstated the trial court's ruling, denying Haddon prejudgment interest. The ruling clarified that while Auto-Owners raised contract-based defenses, the nature of Haddon’s claim remained rooted in personal injury law, which does not permit prejudgment interest.

Impact

This ruling has significant implications for future personal injury cases in Tennessee, particularly those involving uninsured motorists. It reinforces the legal understanding that personal injury claims do not qualify for prejudgment interest, which could affect how plaintiffs approach their claims against uninsured motorist carriers.

The decision may also discourage plaintiffs from pursuing prejudgment interest in similar cases, as the court's ruling sets a clear precedent that aligns with existing Tennessee law. This ruling could lead to more cautious litigation strategies among attorneys representing clients in personal injury cases involving uninsured motorists.

What's Next

As the ruling has been made by the Tennessee Supreme Court, the decision is final unless there are grounds for further appeal to the U.S. Supreme Court, which is not indicated in the current case. There are no related cases pending that would directly affect this ruling.