Tennessee Code Annotated

Tenn. Code Ann. § 1-3-109 (2026)

Section headings and histories

✓ current as of May 2026
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Headings to sections in this code and the references at the end of such sections giving the source or history of the respective sections shall not be construed as part of the law.

T.C.A., § 1-309.


Notes of Decisions
Cited in 16 cases (1 in the last 5 years), 1987–2025 · leading case: State of Tennessee v. Charlotte Lynn Frazier & Andrea Parks, 558 S.W.3d 145 (Tenn. 2018).
State of Tennessee v. Charlotte Lynn Frazier & Andrea Parks, 558 S.W.3d 145 (Tenn. 2018). · cites it 2× “§ 1-3-109 (2014) ("Headings to sections in this code and the references at the end of such sections giving the source or history of the respective sections shall not be construed as part of the law."). Additionally, the State has offered no basis to support a conclusion that the…”
State v. Forbes, 918 S.W.2d 431 (Tenn. Crim. App. 1995). · cites it 2× “See Tenn.Code Ann. § 1-3-109. She further claims that the offense in the body of the statute requires a defendant to “make, present, or use” evidence known to be false, and that the jury's verdict of “fabricating evidence” does not disclose which offense she was convicted of,…”
In Re Est. of Davis, 308 S.W.3d 832 (Tenn. 2010). · cites it 2× “Several factors support the conclusion that the statute is one of limitations, creating a procedural rather than a substantive bar on causes of action filed beyond the two-year period.”
Winter v. Smith, 914 S.W.2d 527 (Tenn. Ct. App. 1995). · cites it 2× “Tenn.Code Ann. § 1-3-109 (1985). Accordingly, the statutes’ licensing requirements broadly apply to all persons engaged in “contracting” as that term is defined in Tenn.”
Saundra Thompson v. Memphis City Schs. Bd. of Educ., 395 S.W.3d 616 (Tenn. 2012). “§ 1-3-109 (2003). Thus, the success of the Board’s argument depends on the text of section 49-5-508(a), and the text does not support the Board’s assertion, but rather provides for a forfeiture of tenure status only if a teacher fails to give thirty days’ notice of her…”
State v. Black, 745 S.W.2d 302 (Tenn. Crim. App. 1987). · cites it 2× “It is first claimed that this statute is unconstitutionally vague in that it fails to define the words “rebellion” and “open violence” so as to properly apprise the defendant of the meaning and scope of this law. We would observe at this point that the word “rebellion” does not…”
Nave v. Nave, 173 S.W.3d 766 (Tenn. Ct. App. 2005). · cites it 2× “Tenn.Code Ann. § 1-3-109 (2003), however, provides that section headings in the code “shall not be construed as part of the law.”
In Re Music City RV, LLC, 304 S.W.3d 806 (Tenn. 2010). · cites it 2× “Acts 2402 , 2539; see also Tenn.Code Ann. § 1-3-109 (2003) (providing that "[hjeadings to sections in this code .”
State of Tennessee v. Russell Matthew Morgan (Tenn. Crim. App. 2025). · cites it 2× “Tenn. Code Ann. § 1-3-109 ; Williams v. Smyrna Residential, LLC, 685 S.”
Marvin Bernatsky & Patricia Bernatsky v. Designer Baths & Kitchens, LLC - Concurring Opinion (Tenn. Ct. App. 2013). · cites it 2× “” Tenn. Code Ann. §1-3-109 . Thus, the legislature has directed courts construing statutes to disregard the language contained in headings in favor of the language utilized in the body of the statute.”
Marvin Bernatsky & Patricia Bernatsky v. Designer Baths & Kitchens, LLC (Tenn. Ct. App. 2013). · cites it 2× “Tenn. Code Ann. § 1-3-109 ; In re Estate of Davis, 308 S.”
State of Tennessee v. Alberto Camacho (Tenn. Crim. App. 2007). · cites it 2× “§ 1-3-109 provides that the headings to statutes are not part of the statutes themselves, it is perfectly permissible under widely accepted principles of statutory construction to look to these headings in the quest to determine legislative intent.”
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