Assigned on Briefs September 1, 2017
from the Chancery Court for Davidson County No. 16-967-II
William E. Young, Chancellor
Clovis ("Plaintiff") appeals the February 7, 2017
order of the Chancery Court for Davidson County ("the
Trial Court") ordering, inter alia, that the
Tennessee Department of Human Services ("the
Department") reinstate Plaintiff's food stamp
benefits. We find and hold that Plaintiff is not an aggrieved
party, and thus, lacks standing to appeal. We, therefore,
dismiss this appeal.
R. App. P. 3 Appeal as of Right; Judgment of the Chancery
Court Dismissed Case Remanded
Quinton Clovis, Nashville, Tennessee, pro se appellant.
Herbert H. Slatery, III, Attorney General and Reporter; and
Ellison M. Berryhill, Assistant Attorney General for the
appellee, Raquel Hatter, Commissioner, Tennessee Department
of Human Services.
MICHAEL SWINEY, C.J., delivered the opinion of the court, in
which ANDY D. BENNETT and KENNY W. ARMSTRONG, JJ., joined.
MEMORANDUM OPINION 
MICHAEL SWINEY, CHIEF JUDGE.
filed suit seeking review of the Department's decision to
discontinue Plaintiff's food stamp benefits. The Trial
Court heard the case and entered its order on February 7,
2017 finding, inter alia, that "the record
demonstrates that [Plaintiff] is exempt from the work
requirement under two separate provisions of the
Department's Food Stamp Program policy, " and
ordering the Department to reinstate Plaintiff's food
stamp benefits. Plaintiff filed a notice of appeal to this
brief on appeal, Plaintiff asks this Court "for a
reversal of the Trial Court Judge's orders, " among
other things. The Department, in its brief on appeal, argues
that Plaintiff is not an aggrieved party and lacks standing
to pursue this appeal.
Court has explained:
Standing is a judge-made doctrine used to determine whether a
party is entitled to judicial relief. Knierim v.
Leatherwood, 542 S.W.2d 806, 808 (Tenn. 1976). It
requires the court to decide whether the party has a
sufficiently personal stake in the outcome of the controversy
to warrant the exercise of the court's power on its
behalf. Browning-Ferris Indus., Inc. v. City of Oak
Ridge, 644 S.W.2d 400, 402 (Tenn. Ct. App. 1982). To
establish standing, a party must demonstrate (1) that it
sustained a distinct and palpable injury, (2) that the injury
was caused by the challenged conduct, and (3) that the injury
is apt to be redressed by a remedy that the court is prepared
to give. Allen v. Wright, 468 U.S. 737, 752, 104
S.Ct. 3315, 3325, 82 L.Ed.2d 556 (1984); Morristown
Emergency & Rescue Squad, Inc. v. Volunteer Dev.
Co., 793 S.W.2d 262, 263 (Tenn. Ct. App. 1990)
("Standing requires not only a distinct and palpable
injury but also a causal connection between the claimed
injury and the challenged conduct."); 13 Charles A.
Wright, et al. Federal Practice and Procedure §
3531.4, at 418 (2d ed. 1984) ("Wright").
The primary focus of a standing inquiry is on the party, not
on the merits of the claim. Valley Forge Christian
College v. Americans United for Separation of Church and
State, 454 U.S. 464, 484, 102 S.Ct. 752, 765, 70 L.Ed.2d
700 (1982); Flast v. Cohen, 392 U.S. 83, 99, 88
S.Ct. 1942, 1952, 20 L.Ed.2d 947 (1968); City
Communications, Inc. v. City of Detroit, 888 F.2d 1081,
1086 (6th Cir. 1989); National Fed'n of Fed.
Employees v. Cheney, 883 F.2d 1038, 1041 (D.C. Cir.
1989). Thus, a party's standing does not depend on the
likelihood of success of its claim on the merits. Hill v.
City of Houston, 764 F.2d 1156, 1159-60 (5th Cir. 1985).
Metro. Air Research Testing Auth., Inc. v. The
Metropolitan Gov't of Nashville and Davidson Cty.,
842 S.W.2d 611, 615 (Tenn. Ct. ...