12 Tennessee opinions name it 2 courts 1994–2026 3 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.
| Case | Followed | Cited |
|---|---|---|
Gamble v. Hospital Corp. of Americagreen2 sentences2001Since 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. 2000Since 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. | 3 | 3 |
Ware v. Meharry Medical Collegegreen1 sentence2021As authorized by Tennessee Code Annotated section 16-15-729,2 de novo appeals to circuit courts from general sessions courts entail “an entirely new trial as if no other trial had occurred and as if the case had originated in the circuit court.” Ware v. Meharry Medical College, 898 S.W.2d 181, 184 (Tenn. 1995) (citing Teague v. Gooch, 333 S.W.2d 1, 3 (Tenn. 1960); Odle v. McCormack, 206 S.W.2d 416, 419 (Tenn. 1947); Braverman v. Roberts Constr. | 1 | 1 |
Teague v. Goochgreen1 sentence2021As authorized by Tennessee Code Annotated section 16-15-729,2 de novo appeals to circuit courts from general sessions courts entail “an entirely new trial as if no other trial had occurred and as if the case had originated in the circuit court.” Ware v. Meharry Medical College, 898 S.W.2d 181, 184 (Tenn. 1995) (citing Teague v. Gooch, 333 S.W.2d 1, 3 (Tenn. 1960); Odle v. McCormack, 206 S.W.2d 416, 419 (Tenn. 1947); Braverman v. Roberts Constr. | 1 | 1 |
Odle v. McCormackgreen1 sentence2021As authorized by Tennessee Code Annotated section 16-15-729,2 de novo appeals to circuit courts from general sessions courts entail “an entirely new trial as if no other trial had occurred and as if the case had originated in the circuit court.” Ware v. Meharry Medical College, 898 S.W.2d 181, 184 (Tenn. 1995) (citing Teague v. Gooch, 333 S.W.2d 1, 3 (Tenn. 1960); Odle v. McCormack, 206 S.W.2d 416, 419 (Tenn. 1947); Braverman v. Roberts Constr. | 1 | 1 |
Alexander v. Foegengreen1 sentence2017See, e.g., Thompson v. Greyhound Lines, Inc., 574 F. App’x 407, 409 (5th Cir. 2014) (“the second complaint does not relate back to the first complaint because the second complaint was not an amendment, but rather the commencement of a separate action”); O’Donnell v. Vencor Inc., 466 F.3d 1104, 1111 (9th Cir. 2006) (explaining that a litigant’s second complaint did not relate back to her first complaint because the second complaint was not an amendment to her first complaint, but rather a separate filing under Federal Rule of Civil Procedure 15); Alexander v. Foegen, 443 F. App’x 333, 334 (10th | 1 | 1 |
O'Donnell v. Vencor, Inc.green1 sentence2017See, e.g., Thompson v. Greyhound Lines, Inc., 574 F. App’x 407, 409 (5th Cir. 2014) (“the second complaint does not relate back to the first complaint because the second complaint was not an amendment, but rather the commencement of a separate action”); O’Donnell v. Vencor Inc., 466 F.3d 1104, 1111 (9th Cir. 2006) (explaining that a litigant’s second complaint did not relate back to her first complaint because the second complaint was not an amendment to her first complaint, but rather a separate filing under Federal Rule of Civil Procedure 15); Alexander v. Foegen, 443 F. App’x 333, 334 (10th | 1 | 1 |
Thompson v. Greyhound Lines, Inc.green1 sentence2017See, e.g., Thompson v. Greyhound Lines, Inc., 574 F. App’x 407, 409 (5th Cir. 2014) (“the second complaint does not relate back to the first complaint because the second complaint was not an amendment, but rather the commencement of a separate action”); O’Donnell v. Vencor Inc., 466 F.3d 1104, 1111 (9th Cir. 2006) (explaining that a litigant’s second complaint did not relate back to her first complaint because the second complaint was not an amendment to her first complaint, but rather a separate filing under Federal Rule of Civil Procedure 15); Alexander v. Foegen, 443 F. App’x 333, 334 (10th | 1 | 1 |
Waldschmidt v. Smith (In Re York)green1 sentence1994The courts have declined to follow the relation-back rule when the application has been lost, Waldschmidt v. Smith (In re York), 43 B.R. 36, 39 (Bankr.M.D.Tenn.1984); when the application has been rejected, Walker v. Ford Motor Credit Co. (In re Clark), 112 B.R. at 231 ; or when the Motor Vehicle Division has erroneously failed to note the lien. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Doyle v. Frostgreen2 sentences2020But 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. 2017“The relation back doctrine does not allow a new cause of action to be filed outside the limitations period[.]” Id. | 1 | 3 |
| Case | Cited | Years |
|---|---|---|
Floyd v. Rentrop
green
2 sentences2026Servs., Inc., we identified three requirements for the relation back analysis under Rule 15.03: [A]n amended complaint changing the name of a party relates back to the date of the original pleading if three requirements are met: “(1) the claim or defense asserted in the amended pleading arose out of the conduct, transaction or occurrence set forth or attempted to be set forth in the original pleading . . . if, within the period provided by law for commencing the action against him, the party to be brought in by amendment (2) has received such -8- notice of the institution of the action that he 2000On August 20, 1984, the Supreme Court denied permission to appeal in the Gamble case and, on the same day, decided Floyd v. Rentrop, 675 S.W.2d 165 (Tenn.1984), another case concerning the relation-back doctrine in the field of medical malpractice. | 2 | 2000–2026 |
Tiller v. Atlantic Coast Line Railroad
green
2 sentences2001Co., 323 U.S. 574 , 65 S.Ct. 421 , 89 L.Ed. 465 (1945)). 2001Co., 323 U.S. 574 , 65 S.Ct. 421 , 89 L.Ed. 465 (1945)). | 2 | 2000–2001 |
Conley v. Burlington Northern Railroad
green
1 sentence2022So the court held that “[t]o the extent that the cases cited by the defendants contain language indicating that a complaint filed in the name of a deceased plaintiff is a nullity for purposes of applying the relation back doctrine, we disagree with those cases.” Id. | 1 | 2022–2022 |
Tiffany Shockley, Individually and as Personal Representative of the Estate of Terry Street v. Mental Health Cooperative, Inc.
green
1 sentence2020Id. at 590 . | 1 | 2020–2020 |
Walker v. Ford Motor Credit Co. (In re Clark)
green
1 sentence1994The courts have declined to follow the relation-back rule when the application has been lost, Waldschmidt v. Smith (In re York), 43 B.R. 36, 39 (Bankr.M.D.Tenn.1984); when the application has been rejected, Walker v. Ford Motor Credit Co. (In re Clark), 112 B.R. at 231 ; or when the Motor Vehicle Division has erroneously failed to note the lien. | 1 | 1994–1994 |
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.
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.