Tennessee Code Annotated
Tenn. Code Ann. § 20-2-214 (2026)
Jurisdiction of persons unavailable to personal service in state - Classes of actions to which applicable
✓ current as of May 2026
- (a) Persons who are nonresidents of this state and residents of this state who are outside the state and cannot be personally served with process within this state are subject to the jurisdiction of the courts of this state as to any action or claim for relief arising from:
- (1) The transaction of any business within this state;
- (2) Any tortious act or omission within this state;
- (3) The ownership or possession of any interest in property located within this state;
- (4) Entering into any contract of insurance, indemnity or guaranty covering any person, property or risk located within this state at the time of contracting;
- (5) Entering into a contract for services to be rendered or for materials to be furnished in this state;
- (6) Any basis not inconsistent with the constitution of this state or of the United States;
- (7) Any action of divorce, annulment or separate maintenance where the parties lived in the marital relationship within this state, notwithstanding one party's subsequent departure from this state, as to all obligations arising for alimony, custody, child support or marital dissolution agreement, if the other party to the marital relationship continues to reside in this state.
- (b) As used in this section, "person" includes corporations and all other entities that would be subject to service of process if present in this state.
- (c) Any such person shall be deemed to have submitted to the jurisdiction of this state who acts in the manner described in subsection (a) through an agent or personal representative.
Acts 1965, ch. 67, § 1; 1972, ch. 689, § 1; 1975, ch. 177, § 1; 1978, ch. 715, § 1; T.C.A., § 20-235; Acts 1987, ch. 390, § 1.
Notes of Decisions
Cited in 168
cases (34 in the last 5 years), 1981–2026 · leading case: Gordon v. Greenview Hosp., Inc., 300 S.W.3d 635 (Tenn. 2009).
Gordon v. Greenview Hosp., Inc., 300 S.W.3d 635 (Tenn. 2009). “Accordingly, Tennessee’s courts later observed that the addition of Tenn. Code Ann. § 20-2-214 (a)(6) converted the long-arm statute from a “single enumerated act” statute to a “minimum contacts” statute that permitted Tennessee courts to exercise personal jurisdiction over…”
Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001). “The issue in this case is whether the Tennessee long arm statute, Tenn.Code Ann. § 20-2-214, and the Fourteenth Amendment to the United States Constitution allow courts in Tennessee to obtain personal jurisdiction over a defendant based on what has been termed the “conspiracy…”
State of Tennessee v. NV Sumatra Tobacco Trading Co., 403 S.W.3d 726 (Tenn. 2013). “Some in the legal community expressed concern that the precise wording of Tenn. Code Ann. § 20-2-214 (a)(6) did not actually stretch Tennessee’s jurisdictional arm quite as long as the General Assembly intended.”
Humphreys v. Selvey, 154 S.W.3d 544 (Tenn. Ct. App. 2004). “Tennessee’s long-arm statute, T.C.A. § 20-2-214 (1994), allows Tennessee courts to exercise jurisdiction to the extent the Fourteenth Amendment of the United States Constitution permits.”
Masada Inv. Corp. v. Allen, 697 S.W.2d 332 (Tenn. 1985). “In asserting their claim against Hockert and Allen, the third-party plaintiffs alleged that they were subject to service of process pursuant to T.C.A. § 20-2-214, the Tennessee long-arm statute.”
First Cmty. Bank, N.A. v. First Tennessee Bank, N.A., 489 S.W.3d 369 (Tenn. 2015). “” Tenn. Code Ann. § 20-2-214 (a) (2009). Additionally, Tennessee Code Annotated section 20-2-225 provides that Tennessee courts may exercise jurisdiction on “any other basis authorized by law” or on “[a]ny basis not inconsistent with the constitution of this State or of the…”
Shelby Mut. Ins. Co. v. Moore, 645 S.W.2d 242 (Tenn. Ct. App. 1981). “Since the original service of process came back “not to be found,” Plaintiff prepared an alias summons which it forwarded to the Secretary of State pursuant to T.C.A. § 20-2-214. The Defendants received this alias summons at their address in Odebolt, Iowa, on September 15, 1980.”
Law Offices of Hugo Harmatz v. Dorrough, 182 S.W.3d 326 (Tenn. Ct. App. 2005). “Tennessee's long-arm statute, Tenn.Code Ann. § 20-2-214, allows Tennessee courts to exercise jurisdiction to the extent the Fourteenth Amendment to the United States Constitution permits.”
Nicholstone Book Bindery, Inc. v. Chelsea House Publishers, 621 S.W.2d 560 (Tenn. 1981). “, § 20-235 (now T.C.A. § 20-2-214), 2 and the constitutional limitations of the Fourteenth Amendment’s due process clause, would not permit jurisdiction under the facts presented.”
J.I. Case Corp. v. Williams, 832 S.W.2d 530 (Tenn. 1992). “The Court stated that three primary factors are to be considered in determining whether the requisite minimum contacts were present, (1) the quantity of the contacts, (2) their nature and quality, and (3) the source and connection of the cause of action with those contacts, as…”
Laura Canaday v. The Anthem Companies, Inc., 9 F.4th 392 (6th Cir. 2021). “Tennessee’s long-arm statute ( Tenn. Code Ann. § 20-2-214 (a)(6)) permits Tennessee courts to exercise jurisdiction to the full extent allowable under the Due Process Clause of the No.”
Landers v. Jones, 872 S.W.2d 674 (Tenn. 1994). “Personal jurisdiction of non-resident defendants may be obtained by service of process under the Tennessee Long Arm Statute (Tenn.Code Ann. § 20-2-214(a)) if, and only if, the non-resident defendant has such minimum contacts with this state that maintenance of the suit does not…”
— Tenn. Code Ann. § 20-2-214(1)(6) — 2 cases
Denton v. Allenbrooke Nursing & Rehab. Ctr. (W.D. Tenn. 2020).
Yarbrough v. Quince Nursing & Rehab. Ctr., LLC (W.D. Tenn. 2022).
— Tenn. Code Ann. § 20-2-214(6) — 6 cases
Simplex Healthcare, Inc. v. Marketlinkx Direct, Inc., 761 F. Supp. 2d 726 (M.D. Tenn. 2011).
Davenport v. State Farm Mut. Auto. Ins. Co., 756 S.W.2d 678 (Tenn. 1988).
Williams v. Williams, 621 S.W.2d 567 (Tenn. Ct. App. 1981).
Willis v. Tri-Cnty. Equip. Co. (W.D. Tenn. 2020).
Exel Transp. Servs., Inc. v. Inter-Ego Sys., Inc. d/b/a Pinnacle Loudspeakers a/k/a Pinnacle Speakers (Tenn. Ct. App. 2008).
— Tenn. Code Ann. § 20-2-214(a) — 19 cases
Gordon v. Greenview Hosp., Inc., 300 S.W.3d 635 (Tenn. 2009). “Accordingly, Tennessee’s courts later observed that the addition of Tenn. Code Ann. § 20-2-214 (a)(6) converted the long-arm statute from a “single enumerated act” statute to a “minimum contacts” statute that permitted Tennessee courts to exercise personal jurisdiction over…”
Landers v. Jones, 872 S.W.2d 674 (Tenn. 1994). “Personal jurisdiction of non-resident defendants may be obtained by service of process under the Tennessee Long Arm Statute (Tenn.Code Ann. § 20-2-214(a)) if, and only if, the non-resident defendant has such minimum contacts with this state that maintenance of the suit does not…”
First Cmty. Bank, N.A. v. First Tennessee Bank, N.A., 489 S.W.3d 369 (Tenn. 2015). “” Tenn. Code Ann. § 20-2-214 (a) (2009). Additionally, Tennessee Code Annotated section 20-2-225 provides that Tennessee courts may exercise jurisdiction on “any other basis authorized by law” or on “[a]ny basis not inconsistent with the constitution of this State or of the…”
Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001). “The issue in this case is whether the Tennessee long arm statute, Tenn.Code Ann. § 20-2-214, and the Fourteenth Amendment to the United States Constitution allow courts in Tennessee to obtain personal jurisdiction over a defendant based on what has been termed the “conspiracy…”
J.I. Case Corp. v. Williams, 832 S.W.2d 530 (Tenn. 1992). “The Court stated that three primary factors are to be considered in determining whether the requisite minimum contacts were present, (1) the quantity of the contacts, (2) their nature and quality, and (3) the source and connection of the cause of action with those contacts, as…”
— Tenn. Code Ann. § 20-2-214(a)(1) — 8 cases
Shelby Mut. Ins. Co. v. Moore, 645 S.W.2d 242 (Tenn. Ct. App. 1981). “Since the original service of process came back “not to be found,” Plaintiff prepared an alias summons which it forwarded to the Secretary of State pursuant to T.C.A. § 20-2-214. The Defendants received this alias summons at their address in Odebolt, Iowa, on September 15, 1980.”
In Re Cardizem CD Antitrust Litig., 105 F. Supp. 2d 618 (E.D. Mich. 2000).
Hagen v. U-Haul Co. of Tennessee, 613 F. Supp. 2d 986 (W.D. Tenn. 2009).
Hilani v. Greek Orthodox Archdiocese, 863 F. Supp. 2d 711 (W.D. Tenn. 2012).
Noval Int'l Resources, LLC v. Andec, Inc., 875 F. Supp. 2d 804 (W.D. Tenn. 2012).
— Tenn. Code Ann. § 20-2-214(a)(2) — 8 cases
Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001). “The issue in this case is whether the Tennessee long arm statute, Tenn.Code Ann. § 20-2-214, and the Fourteenth Amendment to the United States Constitution allow courts in Tennessee to obtain personal jurisdiction over a defendant based on what has been termed the “conspiracy…”
Humphreys v. Selvey, 154 S.W.3d 544 (Tenn. Ct. App. 2004). “Tennessee’s long-arm statute, T.C.A. § 20-2-214 (1994), allows Tennessee courts to exercise jurisdiction to the extent the Fourteenth Amendment of the United States Constitution permits.”
Godwin Aircraft, Inc. v. Houston, 851 S.W.2d 816 (Tenn. Ct. App. 1992).
Sledge v. Indico Sys. Resources, Inc., 68 F. Supp. 3d 834 (W.D. Tenn. 2014).
State Indus., Inc. v. Beckett Gas, Inc., 200 F.R.D. 392 (M.D. Tenn. 2001).
— Tenn. Code Ann. § 20-2-214(a)(3) — 1 case
Law Offices of Hugo Harmatz v. Dorrough, 182 S.W.3d 326 (Tenn. Ct. App. 2005). “Tennessee's long-arm statute, Tenn.Code Ann. § 20-2-214, allows Tennessee courts to exercise jurisdiction to the extent the Fourteenth Amendment to the United States Constitution permits.”
— Tenn. Code Ann. § 20-2-214(a)(5) — 8 cases
Humphreys v. Selvey, 154 S.W.3d 544 (Tenn. Ct. App. 2004). “Tennessee’s long-arm statute, T.C.A. § 20-2-214 (1994), allows Tennessee courts to exercise jurisdiction to the extent the Fourteenth Amendment of the United States Constitution permits.”
Floratine Prods. Grp., Inc. v. Brawley, 282 F. Supp. 2d 798 (W.D. Tenn. 2003).
Troy Noles v. Michigan Powersports, Inc. d/b/a Champion Motorsports & Champion Powersports (Tenn. Ct. App. 2005).
Robert L. Eubanks, Jr. v. Procraft, Inc. (Tenn. Ct. App. 2004).
Samuel Humphreys v. Richard Selvey (Tenn. Ct. App. 2004).
— Tenn. Code Ann. § 20-2-214(a)(6) — 38 cases
Gordon v. Greenview Hosp., Inc., 300 S.W.3d 635 (Tenn. 2009). “Accordingly, Tennessee’s courts later observed that the addition of Tenn. Code Ann. § 20-2-214 (a)(6) converted the long-arm statute from a “single enumerated act” statute to a “minimum contacts” statute that permitted Tennessee courts to exercise personal jurisdiction over…”
MacKey v. Compass Mktg., Inc., 892 A.2d 479 (Md. 2006).
Shelby Mut. Ins. Co. v. Moore, 645 S.W.2d 242 (Tenn. Ct. App. 1981). “Since the original service of process came back “not to be found,” Plaintiff prepared an alias summons which it forwarded to the Secretary of State pursuant to T.C.A. § 20-2-214. The Defendants received this alias summons at their address in Odebolt, Iowa, on September 15, 1980.”
Mull v. All. Mortg. Banking Corp., 219 F. Supp. 2d 895 (W.D. Tenn. 2002).
Mitchell v. White Motor Credit Corp., 627 F. Supp. 1241 (M.D. Tenn. 1986).
— Tenn. Code Ann. § 20-2-214(a)(6)(1994) — 1 case
State Indus., Inc. v. Beckett Gas, Inc., 200 F.R.D. 392 (M.D. Tenn. 2001).
— Tenn. Code Ann. § 20-2-214(a)(7) — 1 case
Harmon L. Maddox v. Tajuana Rochell Maddox (Tenn. Ct. App. 2022).
— Tenn. Code Ann. § 20-2-214(a)(l)(2)(4) — 1 case
Caboodles Cosmetics, Ltd. P'ship v. Caboodles, LLC, 412 F. Supp. 2d 872 (W.D. Tenn. 2006).
— Tenn. Code Ann. § 20-2-214(b) — 2 cases
Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001). “The issue in this case is whether the Tennessee long arm statute, Tenn.Code Ann. § 20-2-214, and the Fourteenth Amendment to the United States Constitution allow courts in Tennessee to obtain personal jurisdiction over a defendant based on what has been termed the “conspiracy…”
White v. Mow It Right, LLC (W.D. Tenn. 2019).
— Tenn. Code Ann. § 20-2-214(c) — 3 cases
Chenault v. Walker, 36 S.W.3d 45 (Tenn. 2001). “The issue in this case is whether the Tennessee long arm statute, Tenn.Code Ann. § 20-2-214, and the Fourteenth Amendment to the United States Constitution allow courts in Tennessee to obtain personal jurisdiction over a defendant based on what has been termed the “conspiracy…”
Williams v. Firstplus Home Loan Owner Trust 1998-4, 310 F. Supp. 2d 981 (W.D. Tenn. 2004).
S & S Screw Mach. Co. v. Cosa Corp., 647 F. Supp. 600 (M.D. Tenn. 1986).
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