Tennessee Code Annotated
Tenn. Code Ann. § 23-2-102 (2026)
Lien on right of action
✓ current as of May 2026
Attorneys and solicitors of record who begin a suit shall have a lien upon the plaintiff's or complainant's right of action from the date of the filing of the suit.
Acts 1899, ch. 243, § 1; Shan., § 3592a1; mod. Code 1932, §8035; Acts 1969, ch. 310, § 1; T.C.A. (orig. ed.), § 29-202.
Notes of Decisions
Cited in 37
cases (6 in the last 5 years), 1981–2026 · leading case: Starks v. Browning, 20 S.W.3d 645 (Tenn. Ct. App. 1999).
Starks v. Browning, 20 S.W.3d 645 (Tenn. Ct. App. 1999). “6 Thus, Tenn.Code Ann. § 23-2-102 now provides that “[attorneys and sohcitors of record who begin a suit shall have a hen upon the plaintiffs or complainant’s right of action from the date of the filing of the suit.”
Schmitt v. Smith, 118 S.W.3d 348 (Tenn. 2003). “” Tenn.Code Ann. § 23-2-102 (1994). This hen “attaches to any proceeds flowing from a judgment, as long as the lawyer worked to secure that judgment for the client.”
Robby's Pancake House of Florida, Inc. v. Walker (In Re Robby's Pancake House of Florida, Inc.), 24 B.R. 989 (Bankr. E.D. Tenn. 1982). “Whelchel Statutory Attorney’s Lien ( Tenn. Code Ann. § 23-2-102 (1980)) H. David Cate Special Master’s Fee ( Tenn.”
Ross v. Scannell, 647 P.2d 1004 (Wash. 1982). “Laws §§ 9-3-1, 9-3-2 (1970); Tenn. Code Ann. § 23-2-102 (1980); Utah Code Ann.”
Jeremy David Parvin v. Jackie LaDean Newman, 518 S.W.3d 298 (Tenn. Ct. App. 2016). “and the fees and expenses of the attorneys of record for the parties in this case pursuant to Tenn. Code Ann. § 23-2-102 , and the Court will enter a separate order for the disbursement of those funds in the following order: first to the payment of the final statement of the…”
Peoples Nat'l Bank of Washington v. King, 697 S.W.2d 344 (Tenn. 1985). “section 23-2-102 where *345 expenses are expressly provided for in the contract with the client.”
In Re Pass, 258 B.R. 170 (Bankr. E.D. Tenn. 2001). “§§ 23-2-102 and/or 23-2-103. Section 23-2-102 directs that “[a]ttorneys and solicitors of record who begin a suit shall have a hen upon the plaintiffs or complainant’s right of action from the date of the filing of the suit.”
Huddleston v. Chesnut (In Re Rector), 14 B.R. 1008 (Bankr. E.D. Tenn. 1981). “They assert they are secured creditors by virtue of T.C.A. § 23-2-102 so that § 547 is not applicable.”
Thomas A. Foster & Assocs., Ltd. v. Paulson, 699 N.W.2d 1 (Minn. Ct. App. 2005). “We note that in those jurisdictions that permit legal malpractice to be raised as a defense to establishment of an attorney lien, the governing statutes do not expressly provide for a summary proceeding.”
Joann Mallinak Glassell v. Richard Lee Glassell, 152 S.W.3d 5 (Tenn. Ct. App. 2004). “In this motion, Crain asserted that he had a lien on all money or other assets awarded to his former client pursuant to Tenn. Code Ann. § 23-2-102 . Crain claimed that because of this lien, he had a property right in Plaintiff’s assets and the Trial Court lacked authority to…”
Walter Walsh v. Ba Inc ., 37 S.W.3d 911 (Tenn. Ct. App. 2000). “filed)-, Tenn.Code Ann. § 23-2-102 (1994). By memorializing the Plaintiffs’ attorneys’ lien in the final judgment, the trial court merely ensured that the lien would continue after entry of the judgment.”
Ambrose, Wilson & Grimm v. Hill (In re Hill), 26 B.R. 52 (Bankr. E.D. Tenn. 1982). “Tenn.Code Ann. § 23-2-102 (1980). But, an attorney’s lien against either his client’s cause of action or judgment is not the functional equivalent of an indebtedness owing to the attorney by the client’s obligor.”
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