Tennessee Code Annotated

Tenn. Code Ann. § 20-4-107 (2026)

Real property - State or agency a party

✓ current as of May 2026
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Notwithstanding any other law or rule of procedure to the contrary, any action the subject matter of which involves real property in which this state, or any agency of this state, is a party, may be properly instituted in any county in which the property is located.

Acts 1981, ch. 493, § 1.


Notes of Decisions
Cited in 9 cases, 1983–2014 · leading case: Sw. Williamson Cnty. Cmty. Ass'n v. Saltsman, 66 S.W.3d 872 (Tenn. Ct. App. 2001).
Sw. Williamson Cnty. Cmty. Ass'n v. Saltsman, 66 S.W.3d 872 (Tenn. Ct. App. 2001). · cites it 21× “29-25-108 and T.C.A. 20-4-107. [[Image here]] Though the Petitioners are seeking a writ of mandamus requiring Commissioner Saltsman to perform certain duties, those duties have a direct relationship to and impact on the land owned by the Petitioners.”
State Ex Rel. Comm'r of the Dep't of Transp. v. Thomas, 336 S.W.3d 588 (Tenn. Ct. App. 2010). · cites it 28× “T.C.A. § 20-4-107 (2009). Thomas contends that the resolution of his claims and defenses against TDOT determines whether Thomas can use his Shelby County property in a way that is economically beneficial.”
Bowden Bldg. Corp. v. Tennessee Real Est. Comm'n, 15 S.W.3d 434 (Tenn. Ct. App. 1999). · cites it 6× “Tenn.Code Ann. § 20-4-107 (1994). Bow-den asserts that the subject matter of this suit involves real property located in Shelby County, Tennessee.”
Williams v. Nicely, 230 S.W.3d 385 (Tenn. Ct. App. 2007). · cites it 4× “” T.C.A. § 20-4-107 (1994). Contrary to Plaintiffs’ assertions, however, this statute addresses venue and does not confer subject matter jurisdiction upon the courts to hear a declaratory judgment action against the State which seeks to construe a state-owned easement.”
Lanius v. Nashville Elec. Serv., 181 S.W.3d 661 (Tenn. 2005). · cites it 2× “Tenn.Code Ann. § 20-4-107 (1994). Grievance actions by state inmates must be brought in the county in which the correctional facility is located.”
Carter v. Olsen, 660 S.W.2d 483 (Tenn. 1983). · cites it 2× “To the Defendant’s argument that the Franklin County Chancery Court lacked jurisdiction to hear the suit, the court cited T.C.A. § 20-4-107 as statutory authority for its jurisdiction.”
State ex rel. Dep't of Transp. v. William H. Thomas, Jr. (Tenn. Ct. App. 2014). · cites it 9× “However, the court 3 noted that Tennessee Code Annotated §20-4-107, related to venue, provides that actions involving “real property in which the State of Tennessee or any agency thereof, is a party, may be properly instituted in any county in which such property is located.”
Bowden Corp. v. Tn Real Est. (Tenn. Ct. App. 1999). · cites it 8× “Tenn. Code Ann. § 20-4-107 (1994). Bowden asserts that the subject matter of this suit involves real property located in Shelby County, Tennessee.”
Anna Lou Williams, Plantation Gardens, D/B/A Tobacco Plantation & Beer Barn D/B/A Jim's Flea Mkt. v. Gerald F. Nicely (Tenn. Ct. App. 2007). · cites it 4× “" T.C.A. § 20-4-107 (1994). Contrary to Plaintiffs' assertions, however, this statute addresses venue and does not confer subject matter jurisdiction upon the courts to hear a declaratory judgment action against the State which seeks to construe a state-owned easement.”
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