Andrew Bettis Aviation, LLC v. Howard Wayne Lanier

Syllabus

This appeal presents two issues: (1) whether Appellant preserved his evidentiary issuesconcerning the trial court's admission of video evidence in a jury trial, and (2) whether,following a bench trial, the trial court made sufficient findings under Rule 52.01 whenrejecting Appellant's COBRA claim. Because Appellant failed to include the evidentiaryissues in a motion for new trial as required by Tennessee Rule of Appellate Procedure 3(e),and because Tennessee Rules of Appellate Procedure 13(b) and 36(b) are not applicable,we conclude that Appellant waived the evidentiary issues. Further, because the trial court'sorder does not make sufficient findings, we cannot conduct a meaningful review of theCOBRA issue, and we remand for compliance with Rule 52.01.