finality requirement (Tennessee) · Go Syfert
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finality requirement in Tennessee

25 Tennessee opinions name it 3 courts 1961–2026 16 in the last five years

The cases below were cited by Tennessee courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Bayberry Associates v. Jonesgreen
tenn · 1990 · cited in 11 Tennessee opinions naming this issue, 2019–2026
2 sentences

2026Although the appellate courts have held that this Court may suspend the finality requirement for good cause shown, “we will not suspend Rule 3 as a mere convenience or to work an end-run around Rule 54.02 of the Tennessee Rules of Civil Procedure, or Rules 9 and 10 of the Tennessee Rules of Appellate Procedure.” Bayberry Assocs. v. Jones, 783 S.W.2d 553, 559 (Tenn. 1990); see also Barton v. Keller, No. W2024-00735-COA-R3-JV, 2025 WL 1091645 , at *4 (Tenn. Ct. App. Apr. 8, 2025).

2024See Bayberry Assocs., 783 S.W.2d at 559 (holding that the finality requirement of Rule 3(a) of the Tennessee Rules of Appellate Procedure could be waived under Tenn. R.

1111
United States v. F. & M. Schaefer Brewing Co.green
scotus · 1958 · cited in 2 Tennessee opinions naming this issue, 2023–2023
2 sentences

2023Schaefer, 356 U.S. at 232 (considering as part of the finality analysis whether the order on appeal “clearly evidences the judge’s intention that it shall be his final act in the case”); Kerr-McGee Chem.

2023Schaefer, 356 U.S. at 232 (considering as part of the finality analysis whether the order on appeal “clearly evidences the judge’s intention that it shall be his final act in the case”); Kerr-McGee Chem.

22
State v. Osbornegreen
tenncrimapp · 1986 · cited in 2 Tennessee opinions naming this issue, 2023–2023
2 sentences

2023For example, in State v. Osborne, 712 S.W.2d 488, 491 (Tenn. Crim.

2023For example, in State v. Osborne, 712 S.W.2d 488, 491 (Tenn. Crim.

22
Kerr-McGee Chemical Corp. v. Lefton Iron & Metal Co.green
ca7 · 2009 · cited in 2 Tennessee opinions naming this issue, 2023–2023
2 sentences

2023Corp. v. Lefton Iron & Metal Co., 570 F.3d 856, 857 (7th Cir. 2009) (reasoning that “[i]f the judge had overlooked [a particular] dispute . . . , then the decision would be final—for the district court would have completed everything it set out to accomplish—and we would remand so that the job could be finished”).

2023Corp. v. Lefton Iron & Metal Co., 570 F.3d 856, 857 (7th Cir. 2009) (reasoning that “[i]f the judge had overlooked [a particular] dispute . . . , then the decision would be final—for the district court would have completed everything it set out to accomplish—and we would remand so that the job could be finished”).

22
Richardson v. Tennessee Board of Dentistrygreen
tenn · 1995 · cited in 1 Tennessee opinions naming this issue, 2025–2025
1 sentence

2025As highlighted by EMCF in its briefing, this Court has previously stated that “[r]es judicata and collateral estoppel apply only if the prior judgment concludes the rights of the parties on the merits.” Richardson v. Tenn. Bd. Of Dentistry, 913 S.W.2d 446, 459 (Tenn. 1995) (citing A.L.

11
Karen Johnson v. Beverly Nunis and Farmer's Insurance Exchangegreen
tennctapp · 2012 · cited in 1 Tennessee opinions naming this issue, 2024–2024
1 sentence

2024Rule 54.02 is “an exception to Rule 3 that permits the trial court, without permission from the appellate court, to certify an order as final and appealable, even if parts of the overall litigation remain pending in the trial court.” Johnson v. Nunis, 383 S.W.3d 122, 130 (Tenn. Ct. App. 2012).

11
Christopher J. White v. Lisa M. Johnson v. City of Memphis, Tennesseegreen
tennctapp · 2016 · cited in 1 Tennessee opinions naming this issue, 2021–2021
1 sentence

2021See White v. Johnson, 522 S.W.3d 417 , 421 n.1 (Tenn. Ct. App. 2016) (citing Bayberry Assocs. v. Jones, 783 S.W.2d 553, 559 (Tenn. 1990) (“[W]e find no bar to the suspension of Rule 3(a).”)).

11
Stacy Foster-Henderson v. Memphis Health Center, Inc.green
tennctapp · 2015 · cited in 1 Tennessee opinions naming this issue, 2021–2021
1 sentence

2021“Except where otherwise provided, this Court only has subject matter jurisdiction over final orders.” Foster-Henderson v. Memphis Health Center, Inc., 479 S.W.3d 214, 222 (Tenn. Ct. App. 2015).

11
State v. Comergreen
tenncrimapp · 2008 · cited in 1 Tennessee opinions naming this issue, 2010–2010
1 sentence

2010See Comer, 278 S.W.3d at 761 ; see also Tenn. Code Ann. § 16-5-108 (a)(1). -2- This court has recently issued diverging opinions concerning whether it has jurisdiction in cases where, as here, the judgment of conviction does not provide the amount of, or set a schedule for, restitution payments.

11
Clements v. Pearsongreen
tenn · 1961 · cited in 1 Tennessee opinions naming this issue, 1997–1997
1 sentence

1997Clements v. Pearson, 352 S.W.2d 236, 237 (Tenn. 1961) (quoting 21 C.J.S.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Parker v. Lambert green
tennctapp · 2006
2 sentences

2021See also, e.g., Hopwood v. Hopwood, No. M2016-01752-COA-R3-CV, 2017 WL 2964886 , at *3 n.4 (Tenn. Ct. App. July 12, 2017) (suspending the finality requirements because of the “the grave nature of proceedings seeking to incarcerate litigants,” despite the fact that the trial court did not rule on a request for attorney’s fees); In Re Estate of Goza, No. W2013-00678-COA- R3-CV, 2014 WL 7235166 , at *3–4 (Tenn. Ct. App. Dec. 19, 2014) (suspending the finality requirement after consideration of “the immense amount of resources already expended in this litigation” in which the parties had “already

2019See also, e.g., Hopwood v. Hopwood, No. M2016-01752-COA-R3-CV, 2017 WL 2964886 , at *3 n.4 (Tenn. Ct. App. July 12, 2017) (suspending the finality requirements because of the “the grave nature of proceedings seeking to incarcerate litigants,” despite the fact that the trial court did not rule on a request for attorney’s fees); In Re Estate of Goza, No. W2013-00678-COA-R3-CV, 2014 WL 7235166 , at *3–4 (Tenn. Ct. App. Dec. 19, 2014) (suspending the finality requirement after consideration of “the immense amount of resources already expended in this litigation” in which the parties had “already a

22019–2021
Briley v. Chapman green
tennctapp · 2005
1 sentence

2016For example, in Briley v. Chapman, 182 S.W.3d 884 (Tenn. Ct. App. 2005), we addressed a situation similar to the one before us here.

12016–2016
Liberty Mutual Insurance v. Wetzel green
scotus · 1976
2 sentences

2011Co. v. Wetzel, 424 U.S. 737, 744 , 96 S.Ct. 1202 , 47 L.Ed.2d 435 (1976))). -4- On April 4, 2011, Tennessee Farmers responded to our March order with a motion to suspend the finality requirement of Rule 3.

2011Co. v. Wetzel, 424 U.S. 737, 744 , 96 S.Ct. 1202 , 47 L.Ed.2d 435 (1976))). -4- On April 4, 2011, Tennessee Farmers responded to our March order with a motion to suspend the finality requirement of Rule 3.

12011–2011
United States v. Denedo green
scotus · 2009
1 sentence

2010United States v. Denedo, 556 U.S. at ___ , 129 S. Ct. at 2223 .

12010–2010
Massey v. Taylor green
tenn · 1868
1 sentence

1961In Massey v. Taylor, 45 Tenn. 447 (1868) a store clerk having been acquitted of a criminal charge of embezzlement sued to recover on a quantum meruit the value of his services up to the time of his discharge; the plea of the defendant store owners that they owed him nothing because of his embezzlement was met by a replication setting up his acquittal in the criminal trial.

11961–1961

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 16-5-108 (3) TN § Tenn. Code Ann. § 27-5-108 (3) TN § Tenn. Code Ann. § 40-35-304 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 61 (1937–2023) PA 47 (1953–2026) CT 34 (1982–2025) CA 30 (1977–2025) FL 30 (1965–2020) NY 29 (1900–2024) MD 29 (1971–2022) DC 27 (1980–2026) TN 25 (1961–2026) MO 25 (1906–2025) HI 21 (1984–2022) AR 20 (1986–2025) VT 20 (1987–2026) IN 18 (1970–2024) MA 17 (1984–2025) IL 16 (1978–2023) AK 16 (1971–2023) WV 16 (1995–2024) GA 14 (1979–2024) OH 14 (1974–2025) WA 14 (1985–2018) MN 14 (1985–2017) NM 14 (1904–2023) AZ 12 (1982–2021) SD 12 (1905–2020) KY 11 (1988–2023) WI 10 (1987–2026) CO 9 (1949–2019) MI 9 (1933–2021) OR 9 (1917–2019) RI 8 (1974–2024) NJ 8 (1912–2017) ID 7 (1981–2023) IA 7 (1932–2025) NE 6 (1970–2017) OK 6 (1915–2006) UT 6 (1994–2024) VI 5 (2002–2010) KS 5 (2001–2017) ND 5 (1988–2021) NV 4 (2013–2021) WY 3 (1985–1989) MT 3 (1978–2006) AL 3 (1899–1946) VA 3 (2005–2024) DE 3 (2010–2021) MS 2 (1991–2013) LA 2 (2002–2004) SC 2 (2010–2026) MP 2 (1999–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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