John P. Konvalinka v. Chattanooga-Hamilton County Hospital Authority

Summary

The Tennessee Supreme Court reversed a Court of Appeals adjudication holding two of Dr. Stratienko's lawyers in civil contempt for filing a separate public-records suit while their interlocutory appeal was pending under a stay of "all proceedings below." The Court held that "proceedings below" means the proceedings in the lower court from which the appeal was taken, so the stay did not clearly and unambiguously prohibit a separate petition under Tenn. Code Ann. § 10-7-505(a), and an ambiguous order cannot support a finding of willful disobedience. The Court also announced the four elements of civil contempt and their standards of review, while reserving for another day whether litigants may use public-records statutes against government entities opposing them in litigation.