Case Citator › Coln v. City of Savannah

Coln v. City of Savannah

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of Tennessee
Citation
966 S.W.2d 34
Decided
Confirmed treatments
1
Flagged citations read
45 of 45
Citing cases (total)
45
Treatment dates
2000
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Coln v. City of Savannah remains controlling on open and obvious dangers, but the Supreme Court of Tennessee clarified its separate discussion of appellate review in Cross v. City of Memphis. Appellate courts review fact findings from a bench trial under Tennessee Rule of Appellate Procedure 13(d).
More on how this was screened

All 45 flagged citations have been read, and the confirmed limitation is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

45 later cases cite Coln v. City of Savannah; 45 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Coln v. City of Savannah?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Supreme Court of Tennessee confined Coln's language about appellate review: fact findings from a bench trial receive de novo review under Rule 13(d), not a clearly erroneous standard.

    Cross v. City of Memphis · Supreme Court of Tennessee · filed

    While it would appear that Rule 13(d) addresses and answers the issue now before this Court, our opinion in Coln v. City of Savannah, 966 S.W.2d 34 (Tenn.1998), has created some confusion with regard to the applicable standard of review. ... Accordingly, we clarify Coin to the extent that it appeared to permit an appellate court to apply a clearly erroneous standard of review to a trial court’s findings of fact.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Coln v. City of Savannah and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace