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Merritt v. Moore
(2026)
Case details
Full caption
KENNETH MERRITT v. BETTY THOMAS MOORE
Country
United States
Jurisdiction
Tennessee (TN)
Court
Tennessee Supreme Court
Decided
2026
Disposition
Remanded
Majority
II (Justice), joined by Andy (Justice), Bennett (Justice), Steven Stafford (Justice)
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE,
Slip
Copy
(2026)
WESTLAW
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
1
2026
WL
2098349
Only
the
Westlaw
citation
is
currently
available.
SEE
COURT
OF
APPEALS
RULES
11
AND
12
Court
of
Appeals
of
Tennessee.
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE
No.
W2025-01131-COA-R3-CV
|
Assigned
on
Briefs
May
1,
2026
|
07/21/2026
Appeal
from
the
Circuit
Court
for
Shelby
County
No.
CT-4667-23
Damita
J.
Dandridge,
Judge
The
plaintiff
filed
this
action
against
a
trial
court
judge
who
had
presided
over
a
prior
lawsuit
involving
the
plaintiff.
The
Shelby
County
Circuit
Court
(“trial
court”)
dismissed
the
plaintiff's
claims,
determining
that
they
were
barred
by
judicial
immunity.
The
plaintiff
timely
appealed.
Because
the
plaintiff
has
failed
to
comply
with
Tennessee
Rule
of
Appellate
Procedure
27
and
Tennessee
Court
of
Appeals
Rule
6
,
we
dismiss
this
appeal.
Tenn.
R.
App.
P.
3
Appeal
as
of
Right;
Appeal
Dismissed
Attorneys
and
Law
Firms
Kenneth
Merritt,
Memphis,
Tennessee,
Pro
Se.
Julia
Marie
Hale
,
Memphis,
Tennessee,
for
the
appellee,
Hon.
Betty
Thomas
Moore.
Thomas
R.
Frierson,
II
,
J.,
delivered
the
opinion
of
the
court,
in
which
Andy
D.
Bennett
,
J.,
and
J.
Steven
Stafford,
P.J.,
W.S.,
joined.
OPINION
IV.
Conclusion
THOMAS
R.
FRIERSON,
II
,
JUDGE
I.
Factual
and
Procedural
Background
*1
On
November
6,
2023,
the
plaintiff,
Kenneth
Merritt,
filed
a
pleading
in
the
trial
court
entitled,
“Lawsuit
Filed
Against
Judge
Betty
Thomas
Moore
for
Procedural
Noncompliance
Leading
to
Case
Dismissal.”
Mr.
Merritt,
acting
without
benefit
of
counsel,
alleged
that
Judge
Moore
had
violated
his
rights
and
had
failed
to
comply
with
local
rules
in
a
separate
proceeding
bearing
case
number
2035473.
Mr.
Merritt
then
detailed
the
various
purported
failings
of
Judge
Moore
in
that
case,
including
her
alleged
failure
to
“update
the
case
file,”
her
failure
to
consolidate
that
case
with
another
pending
matter,
and
her
“mishandling”
of
the
court
docket,
all
of
which
led
to
“the
unfortunate
dismissal
of
Kenneth
Merritt's
case,
CT-1516-22.”
Mr.
Merritt
asserted
that
although
Judge
Moore
would
likely
claim
judicial
immunity,
such
immunity
was
not
absolute
and
did
not
protect
a
judge
regarding
administrative
acts.
Mr.
Merritt
claimed
that
his
constitutional
rights
had
been
violated,
and
based
on
42
United
States
Code
§
1983
,
he
sought
“$500,000
as
compensation
for
the
court's
failure
to
document
all
legal
proceedings.”
In
addition,
he
sought
punitive
damages
in
the
amount
of
$1,000,000.
On
February
5,
2024,
Mr.
Merritt
filed
a
motion
for
default
judgment,
asserting
that
although
he
had
obtained
proper
service
upon
Judge
Moore,
she
had
failed
to
file
an
answer.
On
September
20,
2024,
Judge
Moore
filed
a
motion
to
dismiss
pursuant
to
Tennessee
Rule
of
Civil
Procedure
12.02(6)
,
stating
that
she
had
not
been
properly
served
with
process
until
August
30,
2024.
Judge
Moore
posited
that
Mr.
Merritt's
complaint
should
be
dismissed
because
judicial
immunity
barred
his
claims,
which
were
based
on
the
judicial
act
of
her
dismissal
of
a
previous
lawsuit.
Judge
Moore
also
asserted
that
Mr.
Merritt's
claim
failed
to
meet
the
minimum
pleading
standard
for
a
42
U.S.C.
§
1983
claim
and
was
barred
by
the
applicable
one-year
statute
of
limitations.
Mr.
Merritt
filed
two
separate
responses
opposing
Judge
Moore's
motion
to
dismiss.
Concomitant
with
the
filing
of
his
second
response,
Mr.
Merritt
also
filed
a
“Plaintiff
Statement
of
Undisputed
Facts
in
Support
of
Motion
for
Summary
Judgment”
and
a
“Memorandum
of
Law
in
Support
of
This
Motion
for
Summary
Judgment
Against
Defendant.”
The
record
contains
no
separate
summary
judgment
motion.
However,
Mr.
Merritt's
memorandum
states
that
he
“respectfully
moves
the
Court
for
summary
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE,
Slip
Copy
(2026)
���
WESTLAW
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
2
judgment
pursuant
to
Rule
56
of
the
Tennessee
Rules
of
Civil
Procedure.”
Both
the
memorandum
and
statement
of
undisputed
facts
include
facts
concerning
alleged
procedural
errors
in
prior
cases
identified
as
“2035473”
and
“2065132.”
On
January
9,
2025,
Judge
Moore
filed
a
motion
to
strike
Mr.
Merritt's
statement
of
undisputed
facts
and
memorandum
of
law,
asserting
that
Mr.
Merritt
had
failed
to
comply
with
Tennessee
Rules
of
Civil
Procedure
5.02
and
56.03
.
Mr.
Merritt
filed
a
response
in
opposition,
contending
that
he
had
filed
a
valid
motion
for
summary
judgment
and
that
the
motion
to
strike
should
be
denied.
Mr.
Merritt
then
filed
another
motion
for
default
judgment.
*2
On
April
14,
2025,
Mr.
Merritt
filed
a
“Motion
for
Clarification
or
Reconsideration
and
Renewed
Request
for
Default
Judgment.”
Mr.
Merritt
claimed
that
the
trial
court
had
erred
by
denying
his
motion
for
summary
judgment
without
written
explanation
and
in
the
absence
of
a
response
in
opposition
from
Judge
Moore.
Mr.
Merritt
requested
that
the
court
(1)
reconsider
its
denial
of
his
summary
judgment
motion,
(2)
provide
a
written
ruling
in
his
favor
due
to
Judge
Moore's
alleged
failure
to
respond,
and
(3)
enter
default
judgment
against
Judge
Moore.
Mr.
Merritt
filed
his
affidavits
in
support
of
the
motion.
On
April
21,
2025,
the
trial
court
entered
a
written
order
denying
Mr.
Merritt's
motion
for
summary
judgment
“[f]or
good
cause
shown.”
On
April
25,
2025,
Mr.
Merritt
filed
another
motion
for
default
judgment
against
Judge
Moore
along
with
an
unnotarized
affidavit.
Subsequently,
on
June
2,
2025,
Mr.
Merritt
filed
a
“Memorandum
of
Law
in
Support
of
Plaintiff's
Motion
for
Clarification
Regarding
Denial
of
Summary
Judgment,”
asserting
that
the
trial
court
should
have
provided
a
basis
for
its
ruling
rather
than
simply
finding
“good
cause.”
On
June
4,
2024,
Judge
Moore
filed
a
response
regarding
the
motion
for
default
judgment,
asserting
that
she
had
filed
a
motion
to
dismiss
in
September
2024,
which
had
extended
the
timeframe
within
which
she
was
required
to
file
a
responsive
pleading.
Judge
Moore
stated
that
the
motion
to
dismiss
had
not
yet
been
adjudicated.
On
June
20,
2025,
the
trial
court
entered
an
order
granting
Judge
Moore's
motion
to
dismiss
and
denying
Mr.
Merritt's
motion
for
default
judgment.
The
court
concluded
that
Mr.
Merritt's
claims
were
barred
by
judicial
immunity,
warranting
their
dismissal
pursuant
to
Tennessee
Rule
of
Civil
Procedure
12.02(6)
.
The
court
denied
Mr.
Merritt's
motion
for
default
as
moot.
Meanwhile,
Mr.
Merritt
filed
a
motion
to
stay
the
court's
judgment
of
dismissal,
arguing
that
the
dismissal
was
based
on
a
misapplication
of
the
doctrine
of
judicial
immunity.
On
July
25,
2025,
Mr.
Merritt
filed
a
notice
of
appeal.
Upon
this
Court's
review
of
the
record
on
appeal
to
determine
whether
this
Court
maintained
subject
matter
jurisdiction,
pursuant
to
Tennessee
Rule
of
Appellate
Procedure
13(b)
,
we
concluded
that
the
trial
court's
June
20,
2025
order
was
not
a
final,
effective
judgment
from
which
an
appeal
as
of
right
would
lie.
See
Tenn.
R.
App.
P.
3(a)
.
This
Court
determined
that
the
June
20,
2025
order
failed
to
comply
with
Tennessee
Rule
of
Civil
Procedure
58
because
it
contained
neither
Mr.
Merritt's
signature
nor
a
certificate
of
service
demonstrating
that
it
had
been
served
upon
him.
Accordingly,
this
Court
entered
an
order
remanding
the
matter
to
the
trial
court
for
entry
of
a
final
order.
The
trial
court
submitted
a
final
order
to
this
Court
on
December
29,
2025,
and
this
appeal
proceeded.
II.
Issue
Presented
Although
both
parties
have
raised
issues
for
this
Court's
review
on
appeal,
we
determine
that
the
following
issue
raised
by
the
appellee,
which
we
have
restated
slightly,
is
dispositive:
Whether
Mr.
Merritt's
brief
properly
complies
with
Tennessee
Rule
of
Appellate
Procedure
27
.
III.
Analysis
We
recognize
that
Mr.
Merritt
is
a
pro
se
litigant
and
respect
his
decision
to
proceed
self-represented.
With
regard
to
self-
represented
litigants,
this
Court
has
explained:
Pro
se
litigants
who
invoke
the
complex
and
sometimes
technical
procedures
of
the
courts
assume
a
very
heavy
burden.
Conducting
a
trial
with
a
pro
se
litigant
who
is
unschooled
in
the
intricacies
of
evidence
and
trial
practice
can
be
difficult.
Nonetheless,
trial
courts
are
expected
to
appreciate
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE,
Slip
Copy
(2026)
WESTLAW
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
3
and
be
understanding
of
the
difficulties
encountered
by
a
party
who
is
embarking
into
the
maze
of
the
judicial
process
with
no
experience
or
formal
training.
*3
Irvin
v.
City
of
Clarksville
,
767
S.W.2d
649,
652
(Tenn.
Ct.
App.
1988)
(internal
citations
omitted).
Parties
proceeding
without
benefit
of
counsel
are
“entitled
to
fair
and
equal
treatment
by
the
courts,”
but
we
“must
not
excuse
pro
se
litigants
from
complying
with
the
same
substantive
and
procedural
rules
that
represented
parties
are
expected
to
observe.”
Hessmer
v.
Hessmer
,
138
S.W.3d
901,
903
(Tenn.
Ct.
App.
2003)
.
This
Court
must
“be
mindful
of
the
boundary
between
fairness
to
a
pro
se
litigant
and
unfairness
to
the
pro
se
litigant's
adversary.”
Id
.
Furthermore,
“[p]ro
se
litigants
are
not
...
entitled
to
shift
the
burden
of
litigating
their
case
to
the
courts.”
See
Chiozza
v.
Chiozza
,
315
S.W.3d
482,
487
(Tenn.
Ct.
App.
2009)
.
Tennessee
Rule
of
Appellate
Procedure
27
dictates
the
requirements
for
an
appellant's
brief,
stating
in
pertinent
part:
(a)
Brief
of
the
Appellant.
The
brief
of
the
appellant
shall
contain
under
appropriate
headings
and
in
the
order
here
indicated:
...
(2)
A
table
of
authorities,
including
cases
(alphabetically
arranged),
statutes
and
other
authorities
cited,
with
references
to
the
pages
in
the
brief
where
they
are
cited;
...
(4)
A
statement
of
the
issues
presented
for
review;
(5)
A
statement
of
the
case,
indicating
briefly
the
nature
of
the
case,
the
course
of
proceedings,
and
its
disposition
in
the
court
below;
(6)
A
statement
of
facts,
setting
forth
the
facts
relevant
to
the
issues
presented
for
review
with
appropriate
references
to
the
record;
(7)
An
argument,
which
may
be
preceded
by
a
summary
of
argument,
setting
forth:
(A)
the
contentions
of
the
appellant
with
respect
to
the
issues
presented,
and
the
reasons
therefor,
including
the
reasons
why
the
contentions
require
appellate
relief,
with
citations
to
the
authorities
and
appropriate
references
to
the
record
(which
may
be
quoted
verbatim)
relied
on;
and
(B)
for
each
issue,
a
concise
statement
of
the
applicable
standard
of
review
...
;
(8)
A
short
conclusion,
stating
the
precise
relief
sought.
In
addition
to
the
requirements
of
Rule
27
,
appellants
must
also
comply
with
Tennessee
Court
of
Appeals
Rule
6
concerning
the
content
of
their
briefs.
Rule
6
provides
in
pertinent
part:
(a)
Written
argument
in
regard
to
each
issue
on
appeal
shall
contain:
(1)
A
statement
by
the
appellant
of
the
alleged
erroneous
action
of
the
trial
court
which
raises
the
issue
and
a
statement
by
the
appellee
of
any
action
of
the
trial
court
which
is
relied
upon
to
correct
the
alleged
error,
with
citation
to
the
record
where
the
erroneous
or
corrective
action
is
recorded.
(2)
A
statement
showing
how
such
alleged
error
was
seasonably
called
to
the
attention
of
the
trial
judge
with
citation
to
that
part
of
the
record
where
appellant's
challenge
of
the
alleged
error
is
recorded.
(3)
A
statement
reciting
wherein
appellant
was
prejudiced
by
such
alleged
error,
with
citations
to
the
record
showing
where
the
resultant
prejudice
is
recorded.
(4)
A
statement
of
each
determinative
fact
relied
upon
with
citation
to
the
record
where
evidence
of
each
such
fact
may
be
found.
(b)
No
complaint
of
or
reliance
upon
action
by
the
trial
court
will
be
considered
on
appeal
unless
the
argument
contains
a
specific
reference
to
the
page
or
pages
of
the
record
where
such
action
is
recorded.
No
assertion
of
fact
will
be
considered
on
appeal
unless
the
argument
contains
a
reference
to
the
page
or
pages
of
the
record
where
evidence
of
such
fact
is
recorded.
Taking
into
account
and
respecting
Mr.
Merritt's
pro
se
status,
we
still
must
conclude
that
his
appellate
brief
contains
numerous
significant
deficiencies
with
regard
to
the
above-
listed
requirements.
These
deficiencies
include:
(1)
the
table
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE,
Slip
Copy
(2026)
WESTLAW
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
4
of
authorities
is
inaccurate
because
it
contains
case
citations
that
do
not
appear
in
the
body
of
the
brief,
lists
incorrect
page
numbers
for
many
of
the
case
citations
that
do
appear,
and
contains
at
least
one
case
authority
that
appears
to
be
nonexistent;
(2)
the
statement
of
facts
fails
to
include
any
citations
to
the
record
whatsoever;
and
(3)
the
argument
section
fails
to
include
any
citations
to
the
record
and
fails
to
cite
to
proper
authority
in
some
instances.
We
will
address
each
of
these
failures
in
turn.
*4
With
reference
to
the
table
of
authorities,
we
note
that
its
purpose
is
to
“provide
a
list
of
authorities
and
where
in
the
brief
they
are
cited
in
order
to
facilitate
efficient
appellate
review.”
MidFirst
Bank
v.
Cole
,
No.
W2023-00440-COA-
R3-CV,
2023
WL
8785890,
at
*5
n.10
(Tenn.
Ct.
App.
Dec.
19,
2023)
.
Mr.
Merritt's
table
of
authorities
is
sufficiently
inaccurate
such
that
it
provides
virtually
no
assistance
in
locating
the
authorities
cited
within
the
brief.
The
page
numbers
listed
therein,
purportedly
demonstrating
the
page
upon
which
each
authority
is
to
be
found
in
the
brief,
are
substantially
incorrect.
In
addition,
at
least
four
of
the
cases
cited
in
the
table
of
authorities
do
not
appear
in
the
brief
at
all
despite
having
page
numbers
listed.
Moreover,
one
of
the
case
authorities
cited
does
not
appear
to
exist
inasmuch
as
this
Court
has
been
unable
to
locate
it
utilizing
either
the
case
name,
date,
or
citation
provided.
Accordingly,
Mr.
Merritt's
table
of
authorities
does
not
“facilitate
efficient
appellate
review.”
See
id.
Concerning
the
statement
of
facts,
although
Mr.
Merritt
does
provide
a
somewhat
limited
statement
of
the
facts
in
support
of
his
issues
relating
to
Judge
Moore's
handling
of
the
earlier
lawsuit,
he
includes
no
citations
to
the
record
demonstrating
the
portions
of
the
record
wherein
these
facts
are
established.
In
fact,
Mr.
Merritt's
entire
brief
contains
no
citations
to
the
record
whatsoever.
As
this
Court
has
previously
clarified:
“Courts
have
routinely
held
that
the
failure
to
comply
with
even
one
of
the
Rule
27
requirements
constitutes
a
waiver
of
the
appellate
issue.”
Short
v.
Alston
,
No.
W2022-00666-COA-R3-CV,
2023
WL
5294531,
at
*2
(Tenn.
Ct.
App.
Aug.
17,
2023)
;
see,
e.g.
,
Gates
v.
Switzer
,
No.
M2021-01552-COA-R3-CV,
2023
WL
6296290,
at
*3
(Tenn.
Ct.
App.
Sept.
27,
2023)
(“Wife's
arguments
on
issues
four,
five,
and
nine
fail
to
include
any
citations
to
the
record
and
are
therefore
waived
pursuant
to
Rule
27
and
Rule
6
.”);
Little
v.
City
of
Chattanooga
,
650
S.W.3d
326,
348,
353
(Tenn.
Ct.
App.
2022)
(deeming
various
issues
waived
for
failure
to
cite
to
the
record);
Cnty.
of
Sumner
v.
Kalbes
,
No.
M2020-01119-COA-R3-CV,
2021
WL
4192319,
at
*2
(Tenn.
Ct.
App.
Sept.
15,
2021)
(“[O]ur
courts
have
routinely
held
that
the
failure
to
make
appropriate
references
to
the
record
as
required
by
Rule
27(a)(7)
constitutes
a
waiver
of
the
issue.”)
(quotation
omitted).
State
v.
$133,429
in
U.S.
Currency
,
No.
W2022-01075-COA-
R3-CV,
2023
WL
6843430,
at
*3
(Tenn.
Ct.
App.
Oct.
17,
2023)
(appeal
dismissed
for
appellant's
failure
to
comply
with
Rule
27
regarding
brief).
Finally,
in
the
argument
section
of
Mr.
Merritt's
brief,
he
not
only
fails
to
include
citations
to
the
record,
he
also
fails
to
include
citations
to
relevant
authority
in
support
of
his
arguments.
Although
some
citations
to
authority
concerning
general
legal
propositions
are
accurate,
several
other
citations
do
not
support
the
proposition
for
which
they
are
cited
or
contain
quotes
that
do
not
actually
appear
in
the
cited
authority.
In
addition,
we
reiterate
that
Mr.
Merritt
has
cited
to
at
least
one
case
authority
that
does
not
appear
to
exist.
1
This
Court
has
previously
explained:
[A]
party's
brief
must
“develop
the
theories
or
contain
authority
to
support
the
averred
position
as
required
by
Tennessee
Rules
of
Appellate
Procedure
27(a)
.”
Hawkins
v.
Hart
,
86
S.W.3d
522,
531
(Tenn.
Ct.
App.
2001)
.
Moreover,
“[i]t
is
not
the
role
of
the
courts,
trial
or
appellate,
to
research
or
construct
a
litigant's
case
or
arguments
for
him
or
her,
and
where
a
party
fails
to
develop
an
argument
in
support
of
his
or
her
contention
or
merely
constructs
a
skeletal
argument,
the
issue
is
waived.”
Sneed
v.
Bd.
of
Pro.
Resp.
of
Supreme
Ct.
,
301
S.W.3d
603,
615
(Tenn.
2010)
.
*5
We
also
note
that
the
brief
does
not
cite
the
record.
“Courts
have
routinely
held
that
the
failure
to
make
appropriate
references
to
the
record
and
to
cite
relevant
authority
in
the
argument
section
of
the
brief
as
required
by
Rule
27(a)(7)
constitutes
a
waiver
of
the
issue.”
Bean
v.
Bean
,
40
S.W.3d
52,
55
(Tenn.
Ct.
App.
2000)
(citations
omitted).
Slate
v.
Smiley
Bail
Bonds
,
No.
M2025-00463-COA-R3-CV,
2026
WL
182494,
at
*2-3
(Tenn.
Ct.
App.
Jan.
22,
2026)
(dismissing
appeal
because
the
appellant's
brief
failed
to
comply
with
Rule
27
).
See
Barton
v.
Barton
,
696
S.W.3d
571,
594
(Tenn.
Ct.
App.
2024)
(explaining
that
judges
are
“
‘not
like
pigs,
hunting
for
truffles’
that
may
be
buried
in
the
record,
or,
for
that
matter,
in
the
parties’
briefs
on
appeal.”
(quoting
KENNETH
MERRITT
v.
BETTY
THOMAS
MOORE,
Slip
Copy
(2026)
WESTLAW
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
5
Nunley
v.
Farrar
,
No.
M2020-00519-COA-R3-CV,
2021
WL
1811750,
at
*6
(Tenn.
Ct.
App.
May
6,
2021)
).
In
the
instant
case,
the
deficiencies
within
Mr.
Merritt's
appellate
brief
are
substantial.
As
this
Court
determined
in
Murray
v.
Miracle
,
457
S.W.3d
399,
402
(Tenn.
Ct.
App.
2014)
:
We
are
not
unmindful
of
Plaintiffs’
pro
se
status
and
have
attempted
to
give
them
the
benefit
of
the
doubt
whenever
possible.
Nevertheless,
we
cannot
write
Plaintiffs’
brief
for
them,
and
we
are
not
able
to
create
arguments
or
issues
where
none
otherwise
are
set
forth.
Likewise,
we
will
not
dig
through
the
record
in
an
attempt
to
discover
arguments
or
issues
that
Plaintiffs
may
have
made
had
they
been
represented
by
counsel.
To
do
so
would
place
Defendants
in
a
distinct
and
likely
insurmountable
and
unfair
disadvantage
as
this
Court
would
be
acting
as
Plaintiffs’
attorney.
Similarly,
we
cannot
unfairly
disadvantage
the
appellee
in
this
matter
by
serving
as
Mr.
Merritt's
attorney.
See
id.
Therefore,
Mr.
Merritt's
issues
presented
on
appeal
are
deemed
waived.
See
Bean
v.
Bean
,
40
S.W.3d
52,
54-55
(Tenn.
Ct.
App.
2000)
.
For
the
reasons
stated
above,
the
appeal
of
this
matter
is
dismissed.
The
case
is
remanded
to
the
trial
court
for
collection
of
costs
assessed
below.
Costs
on
appeal
are
assessed
to
the
appellant,
Kenneth
Merritt.
All
Citations
Slip
Copy,
2026
WL
2098349
Footnotes
1
This
Court
has
previously
referred
to
such
fabricated
case
citations
as
“Artificial
Intelligence
hallucinations,”
described
as
“a
widely
reported
phenomenon
in
which
artificial
intelligence
programs
create
new
information
that
has
no
basis
in
fact.”
See
Simmons
v.
Islam
,
No.
M2025-01261-COA-R3-CV,
2026
WL
1431143,
at
*7
(Tenn.
Ct.
App.
May
21,
2026)
(quoting
Margie
Alsbrook,
Untangling
Unreliable
Citations
,
37
Geo.
J.
Legal
Ethics
415,
446
(2024)
).
End
of
Document
©
2026
Thomson
Reuters.
No
claim
to
original
U.S.
Government
Works.
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