TN STATETennessee Supreme Court
2002

Givens v. Mullikin Ex Rel. McElwaney

75 S.W.3d 383Tennessee Supreme Court • Decided 2002Modified
FLAGSHIPBroad IndemnificationFlow-DownCited 228 times

HOLDING

A Tennessee court ruled that an insurance company can be held liable for wrongful acts committed by its defense attorney if the insurer directed, commanded, or knowingly authorized those acts. The insured (the person being defended) is only liable under the same conditions—if they personally directed or authorized the attorney's misconduct. This matters to subcontractors because it clarifies who bears responsibility when a defense attorney acts improperly during a dispute or lawsuit.

KEY FINDINGS

Broad Indemnification

If your insurance company hires a defense attorney who commits abuse of process or other torts, you may be able to sue the insurance company directly—not just the attorney.

Flow-Down

You are not automatically liable for your attorney's misconduct unless you personally directed or authorized it. Passive involvement is not enough.

FULL COURT OPINION