Tennessee Code Annotated

Tenn. Code Ann. § 1-3-121 (2026)

Cause of action under chapter

✓ current as of May 2026
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Notwithstanding any law to the contrary, a cause of action shall exist under this chapter for any affected person who seeks declaratory or injunctive relief in any action brought regarding the legality or constitutionality of a governmental action. A cause of action shall not exist under this chapter to seek damages.

Added by 2018 Tenn. Acts, ch. 621,s 1.


Notes of Decisions
Cited in 11 cases (10 in the last 5 years), 2018–2026 · leading case: Parents' Choice Tennessee v. Jason Golden, in his Off. Capacity as Superintendent of Williamson Cnty. Schs. (Tenn. Ct. App. 2024).
Parents' Choice Tennessee v. Jason Golden, in his Off. Capacity as Superintendent of Williamson Cnty. Schs. (Tenn. Ct. App. 2024). · cites it 12× “The 26 problems for the School Board, however, is that a private right of action applicable to the Plaintiffs’ Common Core Claim is created in Tennessee Code Annotated section 1-3-121. Chapter 3 of Title 1 of the Tennessee Code addresses the “Construction of Statutes.”
Adams v. CoreCivic of Tennessee, LLC (M.D. Tenn. 2024). · cites it 11× “) It also seeks an award of punitive damages against CoreCivic. (Id. at 50.) Finally, in Count 2, the Complaint claims a right to declaratory and injunctive relief against TDOC and Trousdale County under Tenn.”
Paul Blaylock MD JD v. Univ. of Tennessee Martin (Tenn. Ct. App. 2026). · cites it 10× “’” Tenn. Code Ann. § 1-3-121 (Supp. 2021) (emphases added).”
Fox v. Faison (M.D. Tenn. 2023). · cites it 8× “) Count II is a claim pursuant to Tenn. Code Ann. § 1-3-121 based on the violation of Fox’s rights under Article 1, section 19 of the Tennessee Constitution.”
Benjamin Douglas v. Frank Strada, Comm'r of the Tennessee Dep't of Corr. (2024). · cites it 5× “” Relying upon Tenn. Code Ann. § 1-3-121 ,1 Plaintiff asked the Trial Court to declare that Defendants’ actions contravened his rights under Article 1, Section 32 of the Tennessee Constitution.”
George Grant v. Elaine Anderson, Clerk Of Williamson Cnty. (Tenn. Ct. App. 2018). · cites it 4× “(codified at Tenn. Code Ann. § 1-3-121 ). When a statute designates who may bring an action, “his or her right of action arises directly out of the statute, and he or she needs no title under the substantive law to authorize suit.”
Amy Frogge v. Shawn Joseph (Tenn. Ct. App. 2022). · cites it 4× “, and section 1-3-121, in addition to 42 U.S.C.”
Nehad S. Abdelnabi v. Steven Wayne Sword, Judge (Tenn. Ct. App. 2024). · cites it 2× “]” He argued that, under Tennessee Code Annotated section 1-3-121, his action for declaratory or injunctive relief was not barred by the doctrine of sovereign immunity.”
Gary Wygant v. Bill Lee, Governor (Tenn. 2025). · cites it 2× “-5- Annotated section 1-3-121, asking the court to declare both plans unconstitutional, to enjoin the use of the plans, and to order the General Assembly to redraw the maps before the August 2022 primary elections.”
Mayor Lee Harris v. Governor Bill Lee (Tenn. Ct. App. 2026). · cites it 2× “The Chancery Court found that Tenn. Code Ann. § 1-3-121 waived sovereign immunity to allow these government officials to challenge the government’s action.”
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