Tennessee Code Annotated
Tenn. Code Ann. § 23-1-109 (2026)
Party acting as own attorney
✓ current as of May 2026
Any person may conduct and manage the person's own case in any court of this state.
Code 1858, § 3979; Shan., § 5791; Code 1932, § 9982; T.C.A. (orig. ed.), § 29-109.
Notes of Decisions
Cited in 14
cases (5 in the last 5 years), 1995–2026 · leading case: James R. Vandergriff v. Parkridge East Hosp., 482 S.W.3d 545 (Tenn. Ct. App. 2015).
James R. Vandergriff v. Parkridge East Hosp., 482 S.W.3d 545 (Tenn. Ct. App. 2015). “Tenn.Code Ann. § 23-1-109. Therefore, Mother is authorized to represent herself, and Father is authorized to represent himself.”
Wright v. Quillen, 909 S.W.2d 804 (Tenn. Ct. App. 1995). “We find, however, that that question was not a material part of this case and the error, if any, in not submitting this question to the jury, was harmless.”
Bivins v. Hosp. Corp. of Am., 910 S.W.2d 441 (Tenn. Ct. App. 1995). “T.C.A. § 23-1-109. No person shall practice law as an attorney, solicitor, or counselor in this State without a license issued by the Supreme Court of the State.”
Est. of Green v. Carthage Gen. Hosp., Inc., 246 S.W.3d 582 (Tenn. Ct. App. 2007). “The legal premises underlying that conclusion were: (1) a corporation is not a person under Tenn.Code Ann. § 23-1-109, the statute that authorizes any person to conduct and manage his or her “own case in court”; (2) a nonlawyer corporate officer cannot represent a corporation in…”
Old Hickory Eng'g & Mach. Co. v. Henry, 937 S.W.2d 782 (Tenn. 1996). “§ 23-1-109 (1994), that “[a]ny person may conduct and manage the person’s own case in any court of this state,” is not applicable to corporations, even when the person undertaking to act for the corporation is an officer or a shareholder.”
Linda Beard v. James William Branson, 528 S.W.3d 487 (2017). “Tenn. Code Ann. § 23-1-109 (2009) (emphasis added).”
Samuel Chandler v. Cynthia Perkins Frazier a/k/a Cynthia Edwards (Tenn. Ct. App. 2021). “Tenn. Code Ann. § 23-1-109 (2009) (emphasis added).”
Linda Beard v. James William Branson - Rehear (Tenn. Ct. App. 2016). “Tenn. Code Ann. § 23-1-109 . However, the right of self-representation only allows an individual to conduct and manage “the person‟s own case.”
Anthony T. Grose v. David Kustoff (Tenn. Ct. App. 2022). “Tenn. Code Ann. § 23-1-109 . . . . However, the right of self-representation only allows an individual to conduct and manage “the person’s own case in any court of this state.”
Anthony T. Grose, Sr. v. Charles Stone (Tenn. Ct. App. 2024). “Tenn. Code Ann. § 23-1-109 .... However, the right of self-representation only allows an individual to conduct and manage “the person’s own case in any court of this state.”
Christopher Alan Hauser, James Michael Usinger & Ronald James Lyons v. State of Tennessee (Tenn. Crim. App. 2025). “2017) (quoting T.C.A. § 23-1-109) (emphasis in original).”
S. Auto Source Fin., LLC v. Airways Towing & Recovery, LLC (Tenn. Ct. App. 2026). “2017) (quoting Tenn. Code Ann. § 23-1-109 (2009)). “[A] non-attorney may not conduct litigation on behalf of an entity or another individual, because doing so would constitute the unauthorized practice of law.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.