What standard of review does a Tennessee appellate court use for interpreting the orders of a trial judge?
Here is the standard as stated in Hamilton v. Methodist Healthcare Memphis Hospitals, No. W2022-00054-COA-R3-CV (Tenn. Ct. App. Oct. 16, 2023):
Tennessee courts ‘have long recognized that orders and judgments should be construed like other written instruments,’ and their interpretation ‘involves questions of law that are reviewed de novo[.]”’ Konvalinka v. Chattanooga-Hamilton Cnty. Hosp. Auth., 249 S.W.3d 346, 356 n.19 (Tenn. 2008); see, e.g., Loring Just. v. Hanaway, No. E2022-00447-COA-R3 CV, 2023 WL 3451544, at *5 (Tenn. Ct. App. May 15, 2023) (rejecting the argument that the question of whether a juvenile court intended someone to be a court-ordered psychologist was ‘one of fact that a jury should decide’ because the ‘interpretation of a trial court’s order is a question of law we review de novo’) (quotation omitted). To the extent that we are also required to interpret the controlling statutes, issues of statutory interpretation are likewise questions of law. Recipient of Final Expunction Ord. in McNairy Cnty. Cir. Ct. Case No. 3279 v. Rausch, 645 S.W.3d 160, 167 (Tenn. 2022).
‘We construe the language in a court order ‘in light of its usual, natural, and ordinary meaning.’’ Gensci v. Wiser, No. M2019-00442-COA-R3-CV, 2021 WL 752790, at *6 (Tenn. Ct. App. Feb. 26, 2021) (quoting Konvalinka, 249 S.W.3d at 359).
Id. at 11.