T. C. A. § 8-44-101 West's Tennessee Code Annotated Currentness Title 8. Public Officers and Employees Chapter 44. Public Meetings Part 1. General Provisions § 8-44-101. Policy; construction (a) The general assembly hereby declares it to be the policy of this state that the formation of public policy and decisions is public business and shall not be conducted in secret. (b) This part shall not be construed to limit any of the rights and privileges contained in article I, § 19 of the Constitution of Tennessee. CREDIT(S) 1974 Pub.Acts, c. 442, §§ 1, 8. Formerly § 8-4401. RESEARCH REFERENCES ALR Library 34 ALR 5th 591, Attorney-Client Exception Under State Law Making Proceedings by Public Bodies Open to the Public. 38 ALR 3rd 1070, Validity, Construction, and Application of Statutes Making Public Proceedings Open to the Public. CONSTITUTIONAL PROVISIONS Article I, § 19, of the Tennessee Constitution, provides: “That the printing presses shall be free to every person to examine the proceedings of the Legislature; or of any branch or officer of the government, and no law shall ever be made to restrain the right thereof. The free communication of thoughts and opinions, is one of the invaluable rights of man, and every citizen may freely speak, write, and print on any subject, being responsible for the abuse of that liberty. But in prosecutions for the publication of papers investigating the official conduct of officers, or men in public capacity, the truth thereof may be given in evidence; and in all indictments for libel, the jury shall have a right to determine the law and the facts, under the direction of the court, as in other criminal cases.” CROSS REFERENCES Confidentiality of records, see § 10-7-504. Hazardous chemical right-to-know law, confidentiality of proceedings, see § 50-3-2013. LAW REVIEW AND JOURNAL COMMENTARIES Comment: Government--Smith County Education Association v. Anderson: An Exception under the Tennessee Open Meetings Act. Trent Kernodle, 15 Mem. St. U. L. Rev. 116 (1984). LIBRARY REFERENCES Key Numbers Administrative Law and Procedure 124. Westlaw Key Number Search: 15Ak124. Corpus Juris Secundum C.J.S. Public Administrative Law And Procedure § 19. NOTES OF DECISIONS Construction and application 2 County boards 5 Cure for violations 11 Discriminatory decisions 9 Discussions with attorneys 8 Evidence 15 Governing body 4 Local ordinances 17 Nature and scope of relief 16 Parties 14 Pleadings 13 Private corporation 7 Public comment 10 Purpose 3 School boards 6 Standing 12 Validity 1 1. Validity Open Meetings Act, by requiring that any deliberation by governing body toward official decision must be conducted openly, does not infringe rights of free speech of members of governing bodies and does not exercise chilling effect upon free expression. U.S.C.A.Const. Amend. 1; T.C.A. § 8-4401 et seq. Dorrier v. Dark, 1976, 537 S.W.2d 888, rehearing denied 540 S.W.2d 658. Administrative Law And Procedure 124; Constitutional Law 1775 Fact that Open Meetings Act fails to allow closed meetings of governmental bodies under any circumstances does not render Act unreasonable or arbitrary. U.S.C.A.Const. Amend. 14; T.C.A. § 8-4401 et seq. Dorrier v. Dark, 1976, 537 S.W.2d 888, rehearing denied 540 S.W.2d 658. Administrative Law And Procedure 124 A land sale negotiation team is required to abide by the Open Meetings Act, but does not violate the Act by recessing a regular meeting and reconvening the following day. Op.Atty.Gen. No. 07-030, March 15, 2007. 2. Construction and application Open Meetings Act, commonly referred to as Sunshine Law, does not apply to General Assembly; Act does not specifically mention General Assembly, and legislative history of Act does not indicate that General Assembly had itself in mind when it passed Act. Mayhew v. Wilder, 2001, 46 S.W.3d 760, appeal denied, rehearing of denial of appeal denied. States 32 Even if legislature intended to bind itself when it passed Open Meetings Act, commonly referred to as Sunshine Law, the Act would not bind a subsequent General Assembly. Mayhew v. Wilder, 2001, 46 S.W.3d 760, appeal denied, rehearing of denial of appeal denied. States 32 The Open Meetings Act does not require the members of a public body to verbalize or discuss a matter prior to a vote. T.C.A. § 8-44-101 et seq. Baltrip v. Norris, 2000, 23 S.W.3d 336, appeal denied. Municipal Corporations 92 Open Meetings Act is remedial in nature and should, therefore, be construed broadly to promote openness and accountability in government, and to protect the public against closed door meetings at every stage of a government body's deliberation. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Administrative Law And Procedure 124 Open Meetings Act is to be construed most favorably to the public and is all encompassing and applies to every meeting of a governing body except where the statute, on its face, excludes its application. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Administrative Law And Procedure 124 While the Open Meetings Act requires all meetings of entities subject to the Act be open to the public, it does not guarantee all citizens the right to participate in the meetings. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Administrative Law And Procedure 124 Open Meetings Act does not make a distinction between technical and substantive violations of its provisions. T.C.A. § 8-44-101 et seq. Zseltvay v. Metropolitan Government of Nashville and Davidson County, 1998, 986 S.W.2d 581, appeal denied. Administrative Law And Procedure 124 Strict compliance with Open Meetings Act is a necessity if it is to be effective. T.C.A. § 8-44-101 et seq. Zseltvay v. Metropolitan Government of Nashville and Davidson County, 1998, 986 S.W.2d 581, appeal denied. Administrative Law And Procedure 124 Sunshine Law is remedial and should be construed broadly to promote openness and accountability in government, and to protect public against closed door meetings at every stage of a government body's deliberations. T.C.A. §§ 8-44-101 to 8-44-108. Metropolitan Air Research Testing Authority, Inc. v. Metropolitan Government of Nashville and Davidson County, 1992, 842 S.W.2d 611, appeal denied. Administrative Law And Procedure 124 Public Meetings Act is remedial and should be liberally construed in furtherance of its purpose. T.C.A. § 8-44-101 et seq. Neese v. Paris Special School Dist., 1990, 813 S.W.2d 432. Administrative Law And Procedure 124 Open Meetings Act is remedial statute which nullifies actions of public bodies taken in violation of Act, rather than penal statute which imposes imprisonment or fine for violation, and thus requirements of specificity are less stringent in regard to Act. T.C.A. § 8-4401 et seq. Dorrier v. Dark, 1976, 537 S.W.2d 888, rehearing denied 540 S.W.2d 658. Statutes 47 The Open Meetings Act does apply to the audit committee, but does not apply to an internal auditor of a municipality. Op.Atty.Gen. No. 06-060, April 5, 2006. On-site physical inspections of county jails are not ordinarily meetings that are subject to the Open Meetings Act provided the inspectors do not deliberate towards a decision in conjunction with the inspection. Op.Atty.Gen. No. 04-070, April 21, 2004. A city ordinance prohibiting any camera, camcorder, or other photographic equipment from a city board meeting would not violate the First Amendment nor would it violate the Open Meetings Act. Op.Atty.Gen. No. 95-101, Oct. 2, 1995. As a general matter, the organization and conduct of county election commission meetings appears to have been left to the discretion of the county election commissions. Thus, so long as a meeting complies with other statutory requirements, including the Open Meetings Act, Tenn. Code Ann. §§ 8-44-101, et seq., a county election commission may determine the subject matter or issues to be any one meeting, whether separate meetings should be called to discuss separate elections, and whether a city election may be called during a regular county election commission meeting when there is other business to be discussed. Op.Atty.Gen. No. 99-206, Oct. 18, 1999. Meetings of the board or members of a rural electric cooperative operating under § 65-25-201 et seq. are not subject to the Open Meetings Act. Whether the Act applies to meetings of the board or members of a rural electric cooperative organized and operating under a different statute or a private act would require an analysis of the statutes governing such cooperative. Op.Atty.Gen. No. 97-154, Nov. 10, 1997. 3. Purpose Purpose of the Open Meetings Act is satisfied if the ultimate decision is made in accordance with the Act, and that ultimate decision is a new and substantial reconsideration of the issues involved, in which the public is afforded ample opportunity to know the facts and to be heard with reference to the matters at issue. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Administrative Law And Procedure 124 4. Governing body Grievance committee of South Central Human Resource Agency was not “governing body” subject to Open Meetings Act (Sunshine Law). T.C.A. §§ 8-44-101 et seq., 8-44-101(a), 8-44-102, 8-44-102(b)(1), 13-26-103(d), 13-26-104, 13-26-108(3). Hastings v. South Cent. Human Resource Agency, 1991, 829 S.W.2d 679, appeal denied. Administrative Law And Procedure 124; States 45 Where individual college faculties at state university had no authority to affect changes in curriculum of their respective colleges nor did faculties have authority to make recommendations pertaining to curriculum of any authority outside college, law school faculty, with respect to matters pertaining to curricula, did not exercise any governmental authority nor did it have power to make recommendations to governing body that would bring its meetings within provisions of Open Meetings Act. T.C.A. §§ 8-4401 et seq., 8-4402. Fain v. Faculty of College of Law of University of Tennessee, 1977, 552 S.W.2d 752. Colleges And Universities 8(1) Meetings of faculty and state university college of law committees, which were created by the dean, which derived their authority from the dean, and authority of which was to make recommendations to dean, who was not a public body but an administrative officer, did not constitute meetings of “governing body” of public body with authority to make decisions for or recommendations to a public body, and thus were not subject to provisions of Open Meetings Act. T.C.A. §§ 8-4401 et seq., 8-4402. Fain v. Faculty of College of Law of University of Tennessee, 1977, 552 S.W.2d 752. Colleges And Universities 8(1) Since accreditation requirement merely required that faculty have primary or initial responsibility and not final authority and such requirement was guideline, failure to totally comply with which would not result in automatic loss of accreditation, argument that state university college of law faculty had to necessarily perform governmental functions with respect to establishment of institutional policies in order to retain accreditation in compliance with university directive that all colleges be fully accredited by professional accrediting organizations did not demonstrate that law faculty was a governing body within meaning of Open Meetings Act. T.C.A. §§ 8-4401 et seq., 8-4402. Fain v. Faculty of College of Law of University of Tennessee, 1977, 552 S.W.2d 752. Colleges And Universities 8(1) Terms “public,” “governmental,” and “governing bodies,” as used in Open Meetings Act, fall within broader term “government bodies” used in caption of Act, and thus Act is not broader than its caption. Const. art. 2, § 17; T.C.A. § 8-4401 et seq. Dorrier v. Dark, 1976, 537 S.W.2d 888, rehearing denied 540 S.W.2d 658. Statutes 110.1 By its terms, the Open Meetings Act applies to any member of any governing body. As used in the context of the Act, an individual becomes a “member” of a “governing body” when he or she has completed all the requirements necessary to qualify to perform the official duties of a member and his or her term of office has begun. Whether or not any particular individual has become a member under the Act would therefore depend upon the requirements governing qualification for membership on that particular governing body. In the case of an elected city official who is a member of a governing body, these requirements would be governed by the statutes creating the office to which the individual was elected. Typically, an individual who has been elected to an office is not yet qualified to serve until his or her term has begun and he or she has taken the oath of office. Op.Atty.Gen. No. 98-047, March 2, 1998. An individual is subject to the Open Meetings Act so long as he or she is a member of a governing body. If, under the applicable statutes, election to a second city position would automatically disqualify that individual from membership in the governing body, then the Open Meetings Act would no longer apply. Similarly, if an individual has effectively resigned his or her membership in a governing body, then he or she would no longer be subject to the Open Meetings Act as it applies to members of that governing body. An individual would become subject to the Open Meetings Act as it applies to another governing body once he or she has qualified for membership in that governing body and his or her term of office in such governing body has begun. An individual who has merely announced that he or she will resign his or her current office as a member of a governing body is still a member and subject to the Open Meetings Act as it applies to that governing body. Op.Atty.Gen. No. 98-047, March 2, 1998. If a county legislative body creates partisan caucuses and gives them the authority to either make recommendations to or decisions for the county legislative body such caucuses would be governing bodies whose meetings would be subject to the Act. If county legislators, acting as individuals, informally group themselves into partisan caucuses for the purpose of conducting political party business that is not within the authority of the county legislative body, then, in that event, the Act would not apply. The Act explicitly provides, however, that “[n]o ... chance meetings, informal assemblages, or electronic communication shall be used to decide or deliberate public business in circumvention of the spirit or requirements of this part.” Accordingly, if the discussion or deliberation in a party caucus meeting turns to matters over which the caucus members would have authority when acting in their capacity as county legislators, then deliberations should not occur unless the Act is being complied with. Op.Atty.Gen. No. 94-094, Aug. 30, 1994. 5. County boards Evidence did not preponderate against trial court's factual finding that county board of parks and recreation fully discussed and voted upon recommendation as to acquisition of wildlife park, for purposes of determining whether Open Meetings Act was violated, in view of testimony that there had been an open and full discussion of acquisition at a meeting and that a vote had been taken, and considering long interval between meeting in question and time of trial. T.C.A. § 8-44-101 et seq. Zseltvay v. Metropolitan Government of Nashville and Davidson County, 1998, 986 S.W.2d 581, appeal denied. Counties 52 County board of parks and recreation, which had technically violated Open Meetings Act, performed a valid and necessary remedial action by subsequently amending its minutes to reflect that a discussion and vote had been had on acquisition of wildlife park, and it was not obligated to debate the question afresh before doing so. T.C.A. § 8-44-101 et seq. Zseltvay v. Metropolitan Government of Nashville and Davidson County, 1998, 986 S.W.2d 581, appeal denied. Counties 52 County commissioner who, upon learning of vacancy in trustee's office, contacted several of his fellow commissioners by telephone, soliciting their vote, did not violate Open Meetings Act. T.C.A. §§ 8-44-101 et seq., 8-44-102(c). Jackson v. Hensley, 1986, 715 S.W.2d 605. Counties 52 6. School boards Board of education did not violate Tennessee Open Meetings Act by attending gathering at superintendent's house before regularly scheduled meeting, even though superintendent may have spoken with some of the members of the board about some public business, where he did not speak individually or in a group to all of the members or even about the same topics. T.C.A. §§ 8-44-101 et seq., 8-44-102(b)(1), (c, d). Bundren v. Peters, 1989, 732 F.Supp. 1486. Schools 57 Where actions resulting in decision not to rehire headstart program employee after transfer of sponsorship of the program were taken in public meetings, there was no violation of Tennessee Sunshine Act. T.C.A. § 8-4401 (Repealed.) Olmstead v. Community Action Services of Morgan County, Inc., 1980, 494 F.Supp. 699. Schools 63(1) By passage of Open Meetings Act, which contained provision that “All statutes in conflict with this Act are hereby repealed,” legislature intended to repeal statute which allowed local boards of education to hold executive sessions. T.C.A. §§ 8-4401 et seq., 49-212; Const. art. 2, § 17. Dorrier v. Dark, 1976, 540 S.W.2d 658. Schools 46 By amending statute, which allowed local boards of education to hold executive sessions, by substituting the word “local” for the words “county, city and special district” subsequent to enactment of Open Meetings Act, legislature did not intend that local school boards be exempt from provisions of Open Meetings Act, in that executive sessions statute was one of 95 sections affected by amendatory act whose purpose was to regularize statutory language describing local public school systems; such action is insufficient to establish a legislative intent to revive right of local school boards to hold executive sessions in contravention of Open Meetings Act. T.C.A. §§ 8-4401 et seq., 49-212. Dorrier v. Dark, 1976, 540 S.W.2d 658. Schools 57 7. Private corporation Worker who was employed by private company to serve as administrator of city hospital did not establish that his termination was in violation of Tennessee's Open Meetings Act; decision to terminate worker's employment was made solely by company, a private corporation which was not subject to the Act, and even if hospital board members' discussion of worker's termination in an informal setting could be characterized as “deliberations,” board had no power to act on these deliberations since worker was an employee of company, and there was no causal connection between alleged violation of the Act and worker's termination. West's Tenn.Code § 8-44-101 et seq. Perdue v. Quorum Health Resources, Inc., 1996, 934 F.Supp. 919. Municipal Corporations 92 8. Discussions with attorneys Attorney-client exception to the Open Meetings Act applied to informal gathering attended by quorum of school board to consult with board's attorney concerning legal ramifications of bringing charges against principal, in view of possibility of being found in contempt of standing federal district court order to reinstate principal as principal of county high school; no action was taken by board at gathering. T.C.A. § 8-44-101 et seq. Cooper v. Williamson County Bd. of Educ., 1987, 746 S.W.2d 176. Schools 57 Attorney-client exception to Open Meetings Act was applicable to gathering of school board and attorney to discuss settlement offer made by principal in connection with dismissal; board made no decision at gathering and no preliminary deliberations were undertaken by board. T.C.A. § 8-44-101 et seq. Cooper v. Williamson County Bd. of Educ., 1987, 746 S.W.2d 176. Schools 57 Application of the Open Meetings Act to discussions between public bodies and their attorneys regarding pending litigation violates constitutional provisions defining the division of power of the state government and limitations of such powers and, therefore, discussions between a public body and its attorney concerning pending litigation are not subject to the Open Meetings Act so long as the public body is a named party in the lawsuit; however, once any discussion whatsoever begins among members of the public body regarding what action to take based upon advice from counsel, whether it be settlement or otherwise, such discussion shall be open to the public and failure to do so shall constitute a clear violation of the Open Meetings Act. T.C.A. § 8-44-101 et seq.; Const. Art. 2, §§ 1, 2. Smith County Educ. Ass'n v. Anderson, 1984, 676 S.W.2d 328. Administrative Law And Procedure 124 Any attorney who participates or allows himself to be used in a manner that would facilitate a violation of the Open Meetings Act, such as the meeting of a public body with its attorney for the ostensible purpose of discussing pending litigation but where, instead, public business is conducted, would be in direct violation of the Code of Professional Responsibility and subject to appropriate disciplinary measures. T.C.A. § 8-44-101 et seq.; Sup.Ct.Rules, Rule 8, Code of Prof.Resp., Canon 4; EC4-1; DR7-102. Smith County Educ. Ass'n v. Anderson, 1984, 676 S.W.2d 328. Attorney And Client 32(7); Attorney And Client 38 Board of education, which discussed with its attorney and in presence of its chief negotiator a pending suit by county education association alleging that the board had committed unlawful acts in collective bargaining negotiations between the association and the board, did not waive confidentiality of communications to the attorney through presence of the chief negotiator and such discussions were not subject to the Open Meetings Act. T.C.A. §§ 8-44-101 et seq., 23-3-105; Const. Art. 2, §§ 1, 2; Sup.Ct.Rules, Rule 8, Code of Prof. Resp. Canon 4; EC4-1. Smith County Educ. Ass'n v. Anderson, 1984, 676 S.W.2d 328. Privileged Communications And Confidentiality 158; Privileged Communications And Confidentiality 168; Schools 57 9. Discriminatory decisions Discriminatory decision made in violation of Open Meetings Act can serve as basis for discrimination suit even though decision is later declared void for violation of Open Meetings Act; actor who discriminates should not be able to circumvent liability for discrimination merely by violating another law or statute. West's Tenn.Code, § 8-44-101 et seq. Forbes v. Wilson County Emergency Dist. 911 Bd., 1998, 966 S.W.2d 417. Civil Rights 1033(2) 10. Public comment County commission meeting, which was a work session at which it considered a request to rezone a site to “special impact industrial” so as to permit airport relocation, complied with the Open Meetings Act, although plaintiffs challenging the rezoning contended there was no agenda published in the newspaper, and that certain parties were not allowed to speak at the meeting; the commission held an open meeting at a regularly scheduled time, at which it gathered information regarding the rezoning request, and, with respect to public comments, each person had five minutes to speak to the commission. Lewis v. Cleveland Mun. Airport Authority, 2008, 289 S.W.3d 808, appeal denied. Zoning And Planning 1183 City planning commission was not required to hear public comment at all meetings concerning proposed construction of regional shopping mall; each meeting complied with the Sunshine Law, public comment was accepted at at least two of the six meetings conducted, and commission only specifically declined to receive additional public comment at one meeting during which chairman directed that audience member be forcibly removed from the room. T.C.A. §§ 8-44-101, 8-44-108. Whittemore v. Brentwood Planning Com'n, City of Brentwood, 1992, 835 S.W.2d 11, rehearing denied, appeal denied. Zoning And Planning 1423 11. Cure for violations Decision of board of trustees of county general hospital district, following meeting open to public, to ratify and confirm all prior actions by board of directors for preferred provider organization (PPO) failed to cure prior violations of Open Meetings Act concerning closed meetings at which PPO's board decided to limit provider network, where there was no discussion by board of trustees at open meeting which pertained specifically to previously adopted limitation of network of physicians. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Health 294 School board's violation of Open Meetings Act, by approving settlement conditions in private meeting, did not entitle terminated teacher to reinstatement where it was determined, at subsequently held public hearing, that dismissal was warranted. T.C.A. § 8-44-101 et seq. Van Hooser v. Warren County Bd. of Educ., 1991, 807 S.W.2d 230. Schools 147.47 12. Standing In action by parent and teacher association against school board for violation of Public Meetings Act, and to enjoin the enforcement of the allegedly illegal and void decision of that board to close elementary school, parent members of the association who had children attending the elementary school had standing to individually institute the lawsuit, as the allegations of the complaint placed the parents and their children in a position of possibly suffering damages of different character or kind from those suffered by the citizens at large due to the allegedly unlawful acts of the board; thus the association had standing to bring suit in its own name. T.C.A. §§ 8-44-101 to 8-44-201. Curve Elementary School Parent and Teachers' Organization v. Lauderdale County School Bd., 1980, 608 S.W.2d 855. Injunction 114(2) 13. Pleadings Complaint by parent and teacher association against school board for violation of Public Meetings Act was not subject to a motion to strike in its entirety because it was not based upon an insufficient defense, or any redundant, material, impertinent or scandalous matter. Rule of Civil Procedure, Rule 12.06; T.C.A. §§ 8-44-101 to 8-44-201. Curve Elementary School Parent and Teachers' Organization v. Lauderdale County School Bd., 1980, 608 S.W.2d 855. Pleading 352 14. Parties Action by parent and teacher association against school board for violation of Public Meetings Act and to enjoin enforcement of the board's decision to close elementary school was not a class action lawsuit, and thus the chancellor erred in holding that the association was required to make individual members parties to the lawsuit, as such a requirement applies only to class actions. T.C.A. §§ 8-44-101 to 8-44-201; Rules of Civil Procedure, Rule 23.07. Curve Elementary School Parent and Teachers' Organization v. Lauderdale County School Bd., 1980, 608 S.W.2d 855. Associations 20(2) 15. Evidence Evidence in suit by chief of police challenging action of board of aldermen in failing to reappoint chief of police supported finding that there was no violation of Open Meetings Act in discussions between mayor and aldermen concerning the procedure for reappointing chief of police and possibility of placing the plaintiff with the fire department. T.C.A. §§ 8-44-101, 8-44-102. Dingman v. Harvell, 1991, 814 S.W.2d 362, appeal denied. Municipal Corporations 182 16. Nature and scope of relief Injunction permanently enjoining preferred provider organization (PPO) from violating Open Meetings Act and requiring reporting to trial court with regard to its compliance with Act was unduly broad to extent that it further affected all of PPO's preferred provider agreements (PPAs) rather than limiting its reach to afford relief to only physician involved in lawsuit. T.C.A. § 8-44-101 et seq. Souder v. Health Partners, Inc., 1998, 997 S.W.2d 140. Injunction 189 17. Local ordinances A proposed ordinance's blanket ban on bringing video or photographic equipment into an official meeting of the Board of Mayor and Aldermen, as well as its prohibition against taking photographs of anyone at the meetings, would violate Article I, Section 19 of the Tennessee Constitution as implemented by the Open Meetings Act, because the breadth of the proposed total ban goes well beyond that which is reasonably related to the city's legitimate interests. Op.Atty.Gen. No. 95-126, Dec. 28, 1995. Meetings between a single member of the Board and a consultant are not meetings of a governing body under the Open Meetings Act. So long as the members do not use the meetings with the consultant to deliberate toward or to make a decision indirectly, these meetings are not meetings of a governing body subject to the Open Meetings Act. So long as the consultant uses the views of the individual members as a general guide in producing a final list, this practice does not appear to permit the members to vote in secret in violation of § 8-44-104(b). Op.Atty.Gen. No. 99-144, July 30, 1999. T. C. A. § 8-44-101, TN ST § 8-44-101 Current through end of 2010 First Ex. Sess. and with laws from 2010 Reg. Sess., eff. through June 9, 2010 (c) 2010 Thomson Reuters. END OF DOCUMENT (c) 2010 Thomson Reuters. No