Doyle v. Frost, 49 S.W.3d 853 (Tenn. 2001). · Go Syfert
Doyle v. Frost, 49 S.W.3d 853 (Tenn. 2001). Cases Citing This Book View Copy Cite
G Cite
cited 4× by 4 distinct cases, 2013–2015 · 2 courts · …in strict compliance with the terms at p. 858 Topic ↗
cited 3× by 3 distinct cases, 2013–2014 · 2 courts · …compromise the protections afforded by Topic ↗
150 citation events (150 in the last 25 years) across 7 distinct courts.
Strongest positive: Nationwide Mutual Fire Insurance Company v. Memphis Light, Gas, and Water (tennctapp, 2018-12-13) · Strongest negative: Susan Durham v. Estate of Gus Losleben (tennctapp, 2020-12-08)
Treatment trajectory · 2001 → 2026 · click a year to view as-of
2001 2013 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited "but see" Susan Durham v. Estate of Gus Losleben
Tenn. Ct. App. · 2020 · signal: but cf. · confidence high
But cf. Doyle v. Frost, 49 S.W.3d 853, 860 (Tenn. 2001) (holding that Rule 15.03 of the Tennessee Rules of Civil Procedure, pertaining to the relation back doctrine, does not impermissibly extend the statute of limitations in the GTLA); Wade v. Jackson-Madison Cty.
examined Cited as authority (verbatim quote) Nationwide Mutual Fire Insurance Company v. Memphis Light, Gas, and Water (3×) also: Cited "see"
Tenn. Ct. App. · 2018 · signal: see also · quote attribution · 1 verbatim quote · confidence high
the legislature's amendment of 20-1-119 supports the proposition that governmental entities should be treated, for purposes of rule 15.03, like any other party.
discussed Cited as authority (rule) Jospheen Guirguis v. Metropolitan Government of Nashville and Davidson County (2×) also: Cited "see, e.g."
Tenn. Ct. App. · 2025 · confidence medium
Gov’t of Nashville and Davidson Cty., 340 S.W.3d 352, 361 (Tenn. 2011) (quoting Doyle v. Frost, 49 S.W. 3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Amanda Cooper Hearn, as Trustee of the Cooper Family Trust v. Sharon Thomas f/k/a Sharon W. Cooper as Trustee of the Cooper Family Trust
Tenn. Ct. App. · 2025 · confidence medium
“The grant or denial of a motion to amend is within the sound discretion of the trial court, and the court's action will be reversed only for an abuse of discretion.” Sallee, 171 S.W.3d at 825 -26 (citing Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Henderson v. Bush Bros. & Co., 868 S.W.2d 236, 237-38 (Tenn. 1993)).
discussed Cited as authority (rule) Janet Doe v. City of Memphis, Tennessee
unknown court · 2024 · confidence medium
Moreno v. City of Clarksville, 479 S.W.3d 795, 809 (Tenn. 2015). “‘Generally, statutes in derogation of the common law are to be strictly construed and confined to their express terms, and that rule of construction has been expressly incorporated into the [GTLA].’” Id. (quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Fairway Capital Partners, LLC v. Tamaryn Gause
Tenn. Ct. App. · 2024 · confidence medium
As we explained, Tennessee courts seek to resolve cases on their merits, rather than on “‘legal technicalities or procedural niceties.’” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001) (quoting Karash v. Pigott, 530 S.W.2d 775, 777 (Tenn. 1975)).
discussed Cited as authority (rule) Tracey Smith v. Oakwood Subdivision Homeowners Association, Inc.
Tenn. Ct. App. · 2023 · confidence medium
“The grant or denial of a motion to amend is within the sound discretion of the trial court, and the court’s action will be reversed only for an abuse of discretion.” Sallee, 171 S.W.3d at 825 -26 (citing Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Henderson v. Bush Bros. & Co., 868 S.W.2d 236, 237-38 (Tenn. 1993)).
discussed Cited as authority (rule) Penny Lawson v. Hawkins County, TN
unknown court · 2023 · confidence medium
Statutes “in derogation of the common law,” moreover, must be “strictly construed and confined to their express terms.” Moreno v. City of Clarksville, 479 S.W.3d 795, 809 (Tenn. 2015) (quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Robert Crotty v. Mark Flora, M.D. (Concur in Part and Dissent in Part)
unknown court · 2023 · confidence medium
If a statute is in derogation of the common law, it must be “strictly construed and confined to [its] express terms.” Moreno v. City of Clarksville, 479 S.W.3d 795, 809 (Tenn. 2015) (quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Robert Crotty v. Mark Flora, M.D.
Tenn. · 2023 · confidence medium
More importantly, section 29-26-119 is in derogation of the common law collateral source rule, so the statute must “be strictly construed and confined to [its] express terms.’” Moreno v. City of Clarksville, 479 S.W.3d 795, 809 (Tenn. 2015) (quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Smith v. Grant
W.D. Tenn. · 2022 · confidence medium
(ECF No. 49-1 at PageID 1673.) (citing Sutton v. Barnes, 78 S.W.3d 908, 916 (Tenn. Ct. App. 2022), Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001).) The Dyer County Defendants reply that “even if Plaintiff[s] had asserted a negligence claim against Dyer County, said claim would be barred by the statute of limitations.” (ECF No. 51 at PageID 1677.) (formatting altered.) As in their Motion, on Reply, Defendants apply the federal “discovery rule,” contending that “[f]ederal procedural law provides that a plaintiff need not be aware of every detail or person involved in causing the injur…
discussed Cited as authority (rule) Braylon W. v. Armie Walker, M.D.
Tenn. Ct. App. · 2021 · confidence medium
As this limited waiver of immunity provided for in the GTLA is in derogation of the common law, it must be “strictly construed and confined to [its] express terms.” Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001) (quoting Ezell v. Cockrell, 902 S.W.3d 394 , 399 (Tenn. 3 Appellant raises two additional issues: 1) whether the trial court erred in granting a motion to quash notice of a deposition of the defendants involved in this case and 2) whether the trial court erred in granting a motion to dismiss Appellant’s claim for pre-majority medical expenses.
discussed Cited as authority (rule) Regions Bank v. Nathan I. Prager
Tenn. · 2021 · confidence medium
Indeed, the Tennessee Rules of Civil Procedure seek “to [e]nsure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001) (quoting Karash v. Pigott, 530 S.W.2d 775, 777 (Tenn. 1975)).
discussed Cited as authority (rule) Dennis Williamson v. Regional One Health
Tenn. Ct. App. · 2021 · confidence medium
The GTLA carves out exceptions to the general rule of sovereign immunity, which provides that “‘suit may not be brought against a governmental entity unless that governmental entity has consented to be sued.’” Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn. 2001) (quoting Hawks v. City of Westmoreland, 960 S.W.2d 10, 14 (Tenn.1997)); see also Tenn. Const. Art.
discussed Cited as authority (rule) Shirley Grimmett v. Wiseman, Excavating, Inc.
W. Va. · 2020 · confidence medium
“The goal behind Rule 15, as with all the Rules of Civil Procedure, is to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001).
discussed Cited as authority (rule) Andy Aylor v. Fred Carr
Tenn. Ct. App. · 2019 · confidence medium
P. 15.01, “as with all the Rules of Civil Procedure, is ‘to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.’” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001) (quoting Karash v. Pigott, 530 S.W.2d 775, 777 (Tenn. 1975)).
discussed Cited as authority (rule) Lester Eugene Siler v. Charles Scott
Tenn. Ct. App. · 2019 · confidence medium
Gov’t of Nashville and Davidson Cty., 340 S.W.3d 352, 361 (Tenn. 2011) (quoting Doyle v. Frost, 49 S.W. 3d 853, 858 (Tenn. 2001)) (“The GTLA’s waiver of immunity is ‘narrowly confined in its scope.’ ”).
cited Cited as authority (rule) Cheryl Merolla v. Wilson County, Tennessee
Tenn. Ct. App. · 2019 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001) (quoting Ezell v. Cockrell, 902 S.W.2d 394, 399 (Tenn. 1995)).
discussed Cited as authority (rule) Dwayne Cochran v. Town Of Jonesborough, Tennessee
Tenn. Ct. App. · 2019 · confidence medium
Gov’t of Nashville and Davidson Cty., 340 S.W.3d 352, 361 (Tenn. 2011) (quoting Doyle v. Frost, 49 S.W. 3d 853, 858 (Tenn. 2001)) (“The GTLA’s waiver of immunity is ‘narrowly confined in its scope.’”).
discussed Cited as authority (rule) Anthony Holder v. Shelby County, Tennessee
Tenn. Ct. App. · 2017 · confidence medium
Discussion The GTLA carves out exceptions to the general rule of sovereign immunity, which provides that “‘suit may not be brought against a governmental entity unless that governmental entity has consented to be sued.’” Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn. 2001) (quoting Hawks v. City of Westmoreland, 960 S.W.2d 10, 14 (Tenn. 1997)); see also Tenn. Const. Art.
discussed Cited as authority (rule) Larry D. Patton v. Shelby County Government
Tenn. Ct. App. · 2017 · confidence medium
Rule 15.03 does not permit amended pleadings in one lawsuit to relate back to the date of original pleadings in a separate lawsuit that was concluded on the merits long ago.2 “There is [] a fundamental difference between filing a second lawsuit and amending an original, timely-filed complaint.” Doyle v. Frost, 49 S.W.3d 853, 859 (Tenn. 2001).
discussed Cited as authority (rule) Standard Oil Company, Inc. v. Consolidation Coal Company
W. Va. · 2016 · confidence medium
“The goal behind Rule 15, as with all the Rules of Civil Procedure, is to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Brooks, 213 W.Va. at 684 , 584 S.E.2d at 540 (quoting Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001)).
examined Cited as authority (rule) Richard Moreno v. City of Clarksville (8×) also: Cited "see, e.g."
Tenn. · 2015 · confidence medium
Under the doctrine of sovereign immunity, suit “may not be brought against a governmental entity unless that governmental entity has consented to be sued.” Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn.2001) (citing Hawks, 960 S.W.2d at 14 ).
cited Cited as authority (rule) Timothy A. Baxter v. State of Tennessee
Tenn. Ct. App. · 2015 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001).
examined Cited as authority (rule) Erica Wade v. Jackson-Madison County General Hospital District (3×) also: Cited "see"
Tenn. Ct. App. · 2015 · confidence medium
Tenn. Code Ann. § 29-20-201 (c); Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001).
discussed Cited as authority (rule) Larry Sneed v. The City of Red Bank, Tennessee (2×)
Tenn. · 2014 · signal: cf. · confidence medium
App.1995) (holding that the doctrine of sovereign immunity precludes application of the saving statute to save a THRA claim against the State in its capacity as an employer because the saving statute does not expressly apply to the State); cf. Doyle v. Frost, 49 S.W.3d 853, 859 (Tenn. 2001) (explaining the limited rationale of these saving statute cases and declining to apply this rationale to foreclose application of Tennessee Rule of Civil Procedure Rule 15.03 to GTLA claims).
discussed Cited as authority (rule) Sherry Harper v. Bradley County, Tennessee (2×)
Tenn. Ct. App. · 2014 · confidence medium
Tenn. Code Ann. § 29-20-201 (c); Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001).
discussed Cited as authority (rule) Sherry Harper v. Bradley County, Tennessee (2×)
Tenn. Ct. App. · 2014 · confidence medium
Tenn.Code Ann. § 29-20-201(c); Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn.2001).
discussed Cited as authority (rule) Frances Ward v. Wilkinson Real Estate Advisors, Inc
Tenn. Ct. App. · 2013 · confidence medium
An amendment changing the party or the naming of the party by or against whom a claim is asserted relates back if the foregoing provision is satisfied and if, within the period provided by law for commencing an action or within 120 days after commencement of the action, the party to be brought in by amendment (1) has received such notice of the institution of the action that the party will not be prejudiced in maintaining a defense on the merits, and (2) knew or should have known that, but for a mistake concerning the identity of the proper party, the action would have been brought against the…
cited Cited as authority (rule) Walton Cunningham v. Williamson County Hosp. Dist. d/b/a Williamson Med. Ctr.
Tenn. · 2013 · confidence medium
Tenn.Code Ann. § 29—20—201(c); Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn.2001).
cited Cited as authority (rule) Apollo Hair Systems of Nashville, Inc. v. Micromode Medical Limited
Tenn. Ct. App. · 2012 · confidence medium
Sallee v. Barrett, 171 S.W.3d 822, 825-26 (Tenn. 2005) (citing Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Henderson v. Bush Bros. & Co., 868 S.W.2d 236 , 237–38 (Tenn. 1993)).
discussed Cited as authority (rule) Stephanie and Eddie Woodard v. Lawrence B. Gross, M.D., Eduardo v. Basco, M.D., and Methodist Healthcare-Memphis Hospitals
Tenn. Ct. App. · 2012 · confidence medium
Statutes of repose serve a purpose similar to that of statutes of limitation, in that both seek to prevent the “adjudication of stale claims.” See Doyle v. Frost, 49 S.W.3d 853, 859 (Tenn. -9- 2001) (quoting Gamble v. Hosp.
cited Cited as authority (rule) Anna Parker, Administrator of Estate of Wanda Faye Dobbs v. Portland Nursing & Nursing Rehab
Tenn. Ct. App. · 2012 · confidence medium
Sallee v. Barrett, 171 S.W.3d 822, 825-26 (Tenn. 2005) (citing Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Henderson v. Bush Bros. & Co., 868 S.W.2d 236 , 237–38 (Tenn. 1993)).
discussed Cited as authority (rule) Hong Samouth (Sam) Rajvongs v. Dr. Anthony Wright
Tenn. Ct. App. · 2012 · confidence medium
The GTLA is in derogation of the common law of sovereign immunity, so it is strictly construed and is “narrowly confined in its scope.” Sutton v. Barnes, 78 S.W.3d 908, 913 (Tenn. Ct. App. 2002)(quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)).
discussed Cited as authority (rule) Sandra Bellanti and Albert Bellanti v. City of Memphis
Tenn. Ct. App. · 2012 · confidence medium
“The grant or denial of a motion to amend is within the sound discretion of the trial court, and the court’s action will be reversed only for an abuse of discretion.” Sallee v. Barrett, 171 S.W.3d 822, 825-26 (Tenn. 2005) (citing Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Henderson v. Bush Bros. & Co., 868 S.W.2d 236, 237-38 (Tenn. 1993)).
discussed Cited as authority (rule) Walton Cunningham & Phyllis Cunningham ex rel. Phillip Walton Cunningham v. Williamson County Hospital District
Tenn. Ct. App. · 2011 · confidence medium
“The GTLA’s waiver of immunity is ‘narrowly confined in its scope.”’ Id. (quoting Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001); citing Tenn. Code Ann. § 29-20-201 (c) (2000) (stating “any claim for damages must be brought in strict compliance with the terms of this chapter)).
discussed Cited as authority (rule) David Dawson Johnson v. Madison County, Tennessee
Tenn. Ct. App. · 2011 · confidence medium
Id. (citing Tenn. Code Ann. § 29-20 - 201(c) (Supp. 2010); Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001)). “‘One of the terms of the GTLA which demands strict compliance is the statute of limitations.’” Id. (quoting Lynn. 63 S.W.3d at 337 ).
discussed Cited as authority (rule) Monica Whitmore v. Shelby County Government (2×) also: Cited "see, e.g."
Tenn. Ct. App. · 2011 · confidence medium
The Act expressly waives immunity only “in limited and enumerated instances for certain injuries,” Ezell v. Cockrell, 902 S.W.2d 394, 399 (Tenn. 1995) (footnote omitted), and this waiver is “narrowly confined in its scope,” Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001).
cited Cited as authority (rule) Dillingham v. Millsaps
E.D. Tenn. · 2011 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn.2001) (citation omitted).
discussed Cited as authority (rule) Hughes v. Metropolitan Government of Nashville & Davidson County
Tenn. · 2011 · confidence medium
The GTLA’s waiver of immunity is “narrowly confined in its scope.” Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn.2001). “[Sjtatutes which waive immunity of the [governmental entity] from suit are to be construed strictly in favor of the sovereign.” 5 McMahon v. United States, 342 U.S. 25, 27 , 72 S.Ct. 17 , 96 L.Ed. 26 (1951).
cited Cited as authority (rule) Campbell v. Anderson County
E.D. Tenn. · 2010 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn.2001).
discussed Cited as authority (rule) Dalton Reb Hughes and wife, Sandra Hines Hughes v. Metropolitan Government of Nashville and Davidson County, Tennessee
Tenn. Ct. App. · 2010 · confidence medium
Co. of Illinois, 240 S.W.3d 220, 224 (Tenn. 2007) (citing Knox v. Batson, 399 S.W.2d 765, 772 (Tenn. 1966)), while the GTLA’s waiver of immunity is “narrowly defined in its scope.” Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001). -13- 23.61, Volume 1, Larson on Compensation, as follows: ‘The essence of the controversy in horseplay cases is the ambiguous nature of claimant’s own conduct, which may or may not be called a departure from his employer’s business.
discussed Cited as authority (rule) MUTO EX REL. MUTO v. Scott
W. Va. · 2008 · confidence medium
“The goal behind Rule 15, as with all the Rules of Civil Procedure, is to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn.2001) (citations omitted).
discussed Cited as authority (rule) Melody Weston, Personal Representative v. Community Baptist Church of Wilson County
Tenn. Ct. App. · 2007 · confidence medium
The reason is “to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001); Karash v. Pigott, 530 S.W.2d 775, 777 (Tenn. 1975).
cited Cited as authority (rule) Dot Bush Goot v. Metropolitan Government of Nashville & Davidson County
Tenn. Ct. App. · 2005 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 857 (Tenn. 2001); Hawks v. City of Westmoreland, 960 S.W.2d 10, 14 (Tenn. 1997).
discussed Cited as authority (rule) Boggs v. Camden-Clark Memorial Hospital Corp. (2×)
W. Va. · 2004 · confidence medium
As we have stated previously: "The goal behind Rule 15, as with all the Rules of Civil Procedure, is to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties." Brooks v. Isinghood, 213 W.Va. 675, 684 , 584 S.E.2d 531, 540 (2003) (quoting Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn.2001) (citations omitted)) (footnote omitted).
discussed Cited as authority (rule) Bell v. Schell
Wyo. · 2004 · confidence medium
Louis, 760 S.W.2d 112, 114 (Mo.1988); and Doyle v. Frost, 49 S.W.3d 853, 856, 858 (Tenn.2001). [122] We have already noted herein Big Horn River System, 2002 WY 89, 120 , 48 P.3d at 1049 , and Northern Utilities Div. of K N Energy, Inc., 822 P.2d at 848 , as cases where this Court applied the relation back concept to protect water rights and to validate an amended complaint, respectively.
discussed Cited as authority (rule) Thomas K. Bowers v. Gutterguard of Tennessee
Tenn. Ct. App. · 2003 · confidence medium
P. Specifically, it pertains to the technical application of a local rule, which forecloses a litigant's day in court, and the stated goal of the Tennessee Rules of Civil Procedure, which is “to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Doyle v. Frost, 49 S.W. 3d 853, 856 (Tenn. 2001) (quoting Karash v. Pigott, 530 S.W. 2d 775, 777 (Tenn. 1975)).
discussed Cited as authority (rule) Jennifer Biscan v. Franklin Brown
Tenn. Ct. App. · 2003 · confidence medium
“The goal behind Rule 15, as with all the Rules of Civil Procedure, is ‘to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.’” Doyle v. Frost, 49 S.W.3d 853, 856 (Tenn. 2001) (quoting Karash v. Pigott, 530 S. W. 775 , 777 (Tenn. 1975)).
discussed Cited as authority (rule) The Estate of Alonzo Donald Tucker v. Lee M. (2×) also: Cited "see, e.g."
Tenn. Ct. App. · 2003 · confidence medium
Doyle v. Frost, 49 S.W.3d 853, 858 (Tenn. 2001); McCracken v. Brentwood United Methodists, 958 S.W.2d 792, 796 (Tenn. Ct. App. 1997).
Retrieving the full opinion text from the archive…
Edgar Forrest DOYLE, Et Al.
v.
Charles FROST, M.D., Et Al.
Tennessee Supreme Court.
Jul 9, 2001.
49 S.W.3d 853
2001 Tenn. LEXIS 564
Richard J. Myers, Memphis, TN, Attorney for the Appellants, Edgar Forrest Doyle and Brenda Doyle., Jerry D. Kizer, Jr. and Patrick W. Rogers, Jackson, TN, Attorneys for the Appel-lees, Jimmy Pratt, M.D., Bolivar General Hospital, Inc., and West Tennessee Health Care, Inc.
Adolpho A. Birch.
Cited by 78 opinions  |  Published

OPINION

ADOLPHO A. BIRCH, J„

delivered the opinion of the court,

in which E. RILEY ANDERSON, C.J., FRANK F. DROWOTA, JANICE M. HOLDER, and WILLIAM M. BARKER, JJ„ joined.

In this appeal, the plaintiffs contest the trial court’s overruling of a motion to amend their complaint to add the Jackson Madison General Hospital District, a governmental entity, as a party defendant. At issue is the scope of Tenn.R.Civ.P. 15.03, which allows the filing date of certain amendments to a pleading to “relate back” to the date of the filing of the original pleading. We are asked to determine whether Rule 15.03 applies to governmental entities. We conclude that it does and, accordingly, reverse the judgment of the Court of Appeals.

I. Facts and Procedural History

On May 24, 1997, Edgar Forrest Doyle sought emergency treatment at Bolivar General Hospital, Inc. (Bolivar), for a back injury sustained two days earlier. He was examined by Jimmy Pratt, M.D., who diagnosed Doyle’s condition as urinary in[*855] continence, gave him a prescription, and instructed him to consult his family physician for a referral to an orthopedic surgeon. Three days later, on May 27, 1997, Doyle sought emergency treatment for the same condition at Baptist Memorial Hospital in Memphis. Following an examination, he was diagnosed as having sustained a large rupture of the central disk, and he underwent immediate surgery. Following the surgery, he suffered significant, irreversible neurological impairment.

Subsequently, Doyle retained an attorney to investigate his case. The attorney contacted the office of Bolivar’s administrator, who stated that Pratt’s services had been provided to Bolivar through a contract with West Tennessee Healthcare, Inc. (WTH). Thereafter, on May 19, 1998, Doyle and his wife, Brenda Doyle, filed a complaint alleging negligence in the diagnosis and treatment of his back injury. The named defendants included, inter alia, Bolivar, Pratt, and Pratt’s presumed employer, WTH. [1] On May 24, 1998, a copy of the complaint was served upon Jim Moss, who served as president and agent for service of process for Bolivar, WTH, and the entity at issue in this case, Jackson Madison County General Hospital District (Hospital District). [2]

Subsequently, Bolivar and WTH filed responsive pleadings denying that Pratt was an employee of either entity and asserting that WTH was not a proper defendant because it did not have any employees or provide any medical services at times relevant to the Doyles’ cause of action. Likewise, Pratt moved to dismiss the complaint against him, asserting that he was an employee of Hospital District (rather than WTH). [3] The Doyles then filed a motion seeking to amend their complaint pursuant to Tenn. R. Civ. P. 15.03 [4] to name Hospital District as a party defendant. In the motion, counsel for the Doyles asserted by affidavit that Bolivar’s administrator had informed him that Pratt was an employee of WTH. A copy of the motion was served on Hospital District, again through Moss as its agent, on September 14, 1998, 118 days after the filing of the complaint.

In responding to the Doyles’ motion, the trial court found that Hospital District was a governmental entity for the purposes of the Tennessee Governmental Tort Liability Act (GTLA), codified at Tenn.Code Ann. §§ 29-20-101 to 407 (2000). It then denied the motion to amend, holding that the Doyles had not asserted their cause of action against Hospital District within the GTLA’s one-year statute of limitations and[*856] that Rule 15.08 could not extend the limitations period against a governmental entity. The Doyles moved for permission to file an interlocutory appeal pursuant to Tenn.R.App.P. 9, which the trial court granted. On appeal, the Court of Appeals affirmed the decision of the trial court. We granted review to determine whether Rule 15.03 applies to governmental entities. We hold that it does, and accordingly, we reverse the judgment of the Court of Appeals.

II. Standard of Review

Generally, review of the denial of a motion to amend a pleading is governed by an “abuse of discretion” standard. See Henderson v. Bush Bros. & Co., 868 S.W.2d 236, 237-38 (Tenn.1993). In this case, however, our review concerns whether Tenn.R.Civ.P. 15.03 applies to governmental entities. Interpretation of the scope of the Rule is a question of law, for which the standard of review is de novo with no presumption of correctness afforded to the legal determinations of the trial court. Lipscomb v. Doe, 32 S.W.3d 840, 843-44 (Tenn.2000).

III. Analysis

A. Rule 15.03

Rule 15 of the Tennessee Rules of Civil Procedure governs the amendment of pleadings and the service of supplemental pleadings. The goal behind Rule 15, as with all the Rules of Civil Procedure, is “to insure that cases and controversies be determined upon their merits and not upon legal technicalities or procedural niceties.” Karash v. Pigott, 530 S.W.2d 775, 777 (Tenn.1975). Rule 15.03 of Tenn. R. Civ. P. provides in pertinent part:

Whenever the claim or defense asserted in amended pleadings arose out of the conduct, transaction, or occurrence set forth ... in the original pleading, the amendment relates back to the date of the original pleading. An amendment changing the party or the naming of the party ... against whom a claim is asserted relates back if the foregoing provision is satisfied and if, within the period provided by law for commencing an action or within 120 days after commencement of the action, the party to be brought in by amendment (1) has received such notice of the institution of the action that the party will not be prejudiced in maintaining a defense on the merits, and (2) knew or should have known that, but for a mistake concerning the identity of the proper party, the action would have been brought against the party.

In other words, the Rule provides that amendments to the pleadings to substitute or change the name of a party will be considered filed on the date of the original pleading so long as the party affected by the amendment had notice of the suit during the limitations period (or within 120 days of the filing date) and knew or should have known that, but for a mistake as to its identity, the suit would have been brought against it. As noted by courts construing the corresponding federal rule, Fed.R.Civ.P. 15(c), the purpose behind the Rule is to “ameliorate the effect of a statute of limitations where the plaintiff has sued the wrong party but where the right party has had adequate notice of the institution of the action.” Bloomfield Mechanical Contracting, Inc. v. Occupational Safety & Health Review Comm’n, 519 F.2d 1257, 1262 (3d Cir.1975); see also Schiavone v. Fortune, 477 U.S. 21, 38, 106 S.Ct. 2379, 2389, 91 L.Ed.2d 18 (1986) (Stevens, J., dissenting) (noting that the “principal purpose” of the Rule “is to enable a plaintiff to correct a pleading error after the statute of limitations has run if the corree[*857] tion will not prejudice his adversary in any way”).

It is uncontested that except for principles unique to suits against governmental entities, the plaintiffs at bar would be allowed to amend their complaint to add Hospital District as a party defendant under Rule 15.08. As stated by the court below:

The Doyles’ claim against the Hospital District arose out of the same conduct, transaction, or occurrence set forth in the Doyles’ original complaint. Additionally, the Hospital District was served with the Doyles’ original complaint on May 24, 1998 through Jim Moss, its registered agent for service of process. This date was within twelve months of May 27, 1997, the date on which the Doyles’ cause of action accrued. This date was also within 120 days after commencement of the action.... Because the Hospital District received timely notice of the Doyles’ lawsuit, it is unlikely that [it] would be prejudiced in maintaining a defense to this action. Finally, upon being served with the Doyles’ original complaint, the Hospital District knew or should have known that, but for the Doyles’ mistake regarding the identity of Dr. Pratt’s employer, the Doyles would have named the Hospital District as a defendant. Thus, in the instant case, we find that the requirements of Rule 15.03 have been satisfied.

Thus, the sole issue in this case is whether the doctrine of sovereign immunity pre-eludes the application of Rule 15.03 when the defendant sought to be added is a governmental entity.

B. Sovereign Immunity

The doctrine of sovereign immunity historically has been recognized as prohibiting suits against the State and governmental entities. See Hawks v. City of Westmoreland, 960 S.W.2d 10, 14 (Tenn.1997); see also Louis L. Jaffe, Suits Against Governments and Officers: Sovereign Immunity, 77 Harv.L.Rev. 1 (1963). The doctrine has been acknowledged in Tennessee’s common law for over a century and provides that “suit may not be brought against a governmental entity unless that governmental entity has consented to be sued.” Hawks, 960 S.W.2d at 14 (citing Lucius v. City of Memphis, 925 S.W.2d 522, 525 (Tenn.1996)); see also Tenn. Const. Art. I, § 17 (“Suits may be brought against the State in such manner and in such courts as the Legislature may by law direct.”). Since 1973, claims against counties, municipalities, and other local governmental agencies [5] have been governed by the GTLA. See generally Tenn.Code Ann. §§ 29-20-101 to 407 (2000).

The GTLA affirms that these entities generally are to be held immune from suit, [6] but goes on to provide narrow exceptions to the general declaration of immunity, noting inter alia that the entities may be held liable for injuries “proximately caused by a negligent act or omission of any employee [of the governmental entity] within the scope of his employment.”[*858] Tenn.Code Ann. § 29-20-205. Through this provision, the legislature has provided that entities such as Hospital District maybe subject to actions sounding in negligence. The waiver of immunity provided by the GTLA, however, is narrowly confined in its scope. As stated in the GTLA, “any claim for damages must be brought in strict compliance with the terms of this chapter.” Tenn.Code Ann. § 29-20-201(c). This Court has acknowledged the efficacy of this legislative mandate:

The limited waiver of governmental immunity provided for in the Act is in clear derogation of the common law. Generally, statutes in derogation of the common law are to be strictly construed and confined to their express terms, and that rule of construction has been expressly incorporated into the Act....

Ezell v. Cockrell, 902 S.W.2d 394, 399 (Tenn.1995) (citations omitted).

One of the terms of the GTLA which demands this strict compliance is the GTLA’s statute of limitations provision, which states that actions against governmental entities “must be commenced within twelve (12) months after the cause of action arises.” Tenn.Code Ann. § 29-20-305(b). The defendants, relying on the premise that this limitations period must be strictly construed, contend that Hospital District is immune from suit because it was not actually named as a party within the twelve-month statute of limitations. We are not persuaded by this argument because we do not find the statute of limitations provision of the GTLA, even when strictly construed, to be in conflict with Rule 15.03. In the most basic terms, an amendment under Rule 15.03 made pursuant to the “relation back” doctrine is not considered excepted from the applicable statute of limitations, it is considered made before the limitations period expired. Cf Black’s Law Dictionary (6th ed.1990) (defining “relation back” as “[a] principle that an act done today is considered to have been done at an earlier time”).

Though the GTLA requires strict compliance with its terms, it does not require that applicable rules of civil procedure be ignored. The GTLA provides that suits under its provisions may be instituted, as was done in this case, in circuit court, [7] and the Tennessee Rules of Civil Procedure “govern the procedure in the circuit and chancery courts of Tennessee.” Tenn. R.Civ.P. 1. Because an amendment to add a party under Rule 15.03 “relates back to the date of the original pleading,” the filing of the action against Hospital District in this case is deemed to have occurred on the date the original complaint was filed, well within the twelve-month statute of limitations.

We reject the defendants’ argument that the application of Rule 15.03 to a party with timely notice of the action extends the statute of limitations or otherwise enlarges the time period for filing suits against a governmental entity. In order for an amendment to relate back under Rule 15.03, the party affected must receive notice of the suit within the limitations period or within 120 days of the commencement of the action, for, as this Court noted in Floyd v. Rentrop, “notice is the critical element involved in determining whether amendments to pleadings relate back.” 675 S.W.2d 165, 168 (Tenn. 1984). Because Rule 15.03 thus requires that the affected party receive sufficient notice of the action, the “relation back” doctrine embodied by the Rule does not compromise the protections afforded by the statute of limitations. As stated by[*859] the Court of Appeals in Gamble v. Hospital Corp. of America,

The purpose of the statute of limitations is to avoid adjudication of stale claims and to give defendants notice to preserve their evidence. Since the relation back doctrine ameliorates the bar of the statute of limitations, if courts evaluate whether an amendment may relate back in terms of notice, in addition to the statutory requirement of same conduct, transaction, or occurrence, then the defendant still has all the protection that the statute of limitations was intended to give.

676 S.W.2d 340, 343 (Tenn.Ct.App.1984) (citing Tiller v. Atlantic Coast Line R. Co., 323 U.S. 574, 65 S.Ct. 421, 89 L.Ed. 465 (1945)).

We are also not persuaded by those cases relied upon by the intermediate court holding that governmental entities are subject to neither (1) “savings statute” provisions nor (2) the joinder provision applicable in comparative fault cases. These holdings may be distinguished from the issue posed by the present case.

The savings statute cases cited by the Court of Appeals focus upon whether governmental entities are subject to the provisions of Tenn.Code Ann. § 28-1-105 (1999), which allows commencement of a new action within one year after a nonsuit, dismissal without prejudice, reversal, or arrest; or Tenn.Code Ann. § 28-1-115 (1999), which allows commencement of a new action in state court within one year after a federal court dismisses a case for lack of jurisdiction. See Nance v. City of Knoxville, 883 S.W.2d 629 (Tenn.Ct.App.1994); Rael v. Montgomery County, 769 S.W.2d 211 (Tenn.Ct.App.1988); Williams v. Memphis Light, Gas, and Water Div., 773 S.W.2d 522 (Tenn.Ct.App.1988). In each of these cases, the plaintiffs’ original lawsuits, filed within the twelve-month limitations period, were dismissed. Each of the plaintiffs then filed a new action after the expiration of the limitations period, following the procedures outlined in the applicable savings statutes. And in each of the cases, the Court of Appeals held that the statutes could not be used to “extend the period” within which an action must be filed against a governmental entity. Nance, 883 S.W.2d at 631-32; Rael, 769 S.W.2d at 213-14; Williams, 773 S.W.2d at 523.

There is, however, a fundamental difference between filing a second lawsuit and amending an original, timely-filed complaint. In each of the savings statute cases, the plaintiffs initiated a new action after the statute of limitations expired, and they sought to rely upon the applicable savings statutes to provide an exception to the time bar created by the statute of limitations. In the case before the Court, however, no new action has been initiated after the expiration of the limitations period. Rather, the Doyles merely seek to amend a complaint which was timely filed. The relation back doctrine does not allow a new cause of action to be filed outside the limitations period, but only allows amendments as to party defendants with timely notice of the action. Because those amendments are deemed filed on the date of the original pleading, the savings statute cases are not analogous to the pending case.

More directly applicable are the intermediate court’s holdings concerning the comparative fault joinder provision, Tenn. Code Ann. § 20-1-119 (1999). This statute applies in comparative fault cases when a plaintiff has sued a defendant and the defendant alleges, after the statute of limitations has expired, that a nonparty caused or contributed to the plaintiffs injury. The statute provides:

[*860] [I]f the plaintiffs cause or causes of action against such person would be barred by any applicable statute of limitations but for the operation of this section, the plaintiff may, within ninety (90) days of the filing of the first answer or first amended answer alleging such person’s fault, either: “(1) Amend the complaint ... pursuant to Rule 15 ...; or (2) Institute a separate action against that person. ...”

Tenn.Code Ann. § 20 — 1—119(a). In Daniel v. Hardin County Gen. Hosp., the Court of Appeals concluded that the GTLA precluded application of this joinder provision to governmental entities because doing so effectively would extend the twelve-month statute of limitations period. 971 S.W.2d 21, 25 (Tenn.Ct.App.1997). In so holding, the court noted that the statute appeared to evince a legislative intent not to allow joinder of governmental entities, noting, “The legislature could have made [Tenn. Code Ann.] § 20-1-119 applicable to the [GTLA], however, it has chosen not to do so.” Id. In the wake of Daniel,however, the legislature has amended the joinder statute to explicitly provide that “[n]ot-withstanding any provision of law to the contrary, this section applies to suits involving governmental entities.” Tenn. Code Ann. § 20-l-119(g) (amendment effective June 15, 1999). Given the legislature’s reaction to Daniel, we find reference to the analysis of that case unpersuasive. To the contrary, the legislature’s amendment of the joinder statute supports the proposition that governmental entities should be treated, for the purposes of Rule 15.03, like any other party.

In sum, we hold that the relation back doctrine embodied in Rule 15.03 does not extend or enlarge the applicable statute of limitations period, for amendments pursuant to the rule are considered filed on the date of the original, timely pleading, and such amendments only may be made if the Rule’s notice requirements are met. The Rule does not compromise the protections afforded by the statute of limitations provision of the GTLA, even when that provision is strictly construed. Thus, no reason exists to preclude application of Rule 15.03 to governmental entities. Accordingly, the Doyles may amend their complaint pursuant to the Rule to add Hospital District as a party defendant.

IV. Conclusion

For the foregoing reasons, we conclude that the doctrine of sovereign immunity does not preclude the application of Rule 15.03 when the party sought to be added by an amendment to the pleadings is a governmental entity. Accordingly, we reverse the denial of the plaintiffs’ motion to amend their complaint, and we remand the cause for further proceedings consistent with this opinion. Costs on this appeal are charged to Jimmy Pratt, M.D., Bolivar General Hospital, Inc., and West Tennessee Healthcare, Inc., for which execution may issue if necessary.

1

. Also named as defendants were Doyle’s family physician, Charles Frost, M.D.; the clinic in which Frost practiced (the Jackson Clinic Professional Association); Paul Jackson, M.D.; and Jackson's employer, NES Mid-South, Inc.

2

. According to Moss's affidavit, Bolivar operates a hospital, WTH owns and leases real property, and Hospital District operates as the "sole member” of these two entities. For both a history of the Hospital Authority Act, which enables the business structure utilized by the defendants, and a discussion of the creation of Hospital District, see Eye Clinic, P.C. v. Jackson-Madison County Gen. Hasp., 986 S.W.2d 565, 568-69 (Tenn.Ct.App.1998). See also Finister v. Humboldt Gen. Hosp., 970 S.W.2d 435, 438-40 (Tenn.1998).

3

. The Tennessee Governmental Tort Liability Act provides that in order to maintain a medical malpractice action against a health care practitioner who is employed by a governmental entity, that entity must be named as a defendant. Tenn.Code Ann. § 29-20-310(b) (1999).

4

. Under Tenn.R.Civ.P. 15.03, an amendment to the pleadings changing the party or naming an additional party against whom a claim is asserted will "relate back” to the date of the original pleading if the requirements of the rule are met.

5

. The GTLA does not apply to claims against the State. See Lucius v. City of Memphis, 925 S.W.2d 522, 525 (Tenn.1996). Claims against the State generally are governed by Tenn. Code Ann. §§ 9-8-101 to 407 (2000).

6

. See Tenn.Code Ann. § 29-20-201(a) ("Except as may be otherwise provided in this chapter, all governmental entities shall be immune from suit for any injury which may result from the activities of such governmental entities wherein such governmental entities are engaged in the exercise and discharge of any of their functions....”).

7

. Term-Code Ann. § 29-20-305.