Tennessee Code Annotated

Tenn. Code Ann. § 23-3-105 (2026)

Privileged communications

✓ current as of May 2026
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No attorney, solicitor or counselor shall be permitted, in giving testimony against a client or person who consulted the attorney, solicitor or counselor professionally, to disclose any communication made to the attorney, solicitor or counselor as such by such person during the pendency of the suit, before or afterward, to the person's injury.

Code 1858, § 3973 (deriv. Acts 1821, ch. 66, § 3); Shan., §5785; mod. Code 1932, § 9978; T.C.A. (orig. ed.), § 29-305.


Notes of Decisions
Cited in 41 cases (7 in the last 5 years), 1981–2025 · leading case: State of Tennessee v. Noura Jackson, 444 S.W.3d 554 (Tenn. 2014).
State of Tennessee v. Noura Jackson, 444 S.W.3d 554 (Tenn. 2014). · cites it 4× “3d 203 , *599 212 (Tenn.Ct.App.2002). The attorney-client privilege, recognized both at common law and by statute, is the oldest privilege in this State and one a witness may invoke.”
Bryan v. State, 848 S.W.2d 72 (Tenn. Crim. App. 1992). · cites it 6× “T.C.A. § 23-3-105 provides that “[n]o attorney .”
Dialysis Clinic, Inc. v. Kevin Medley, 567 S.W.3d 314 (Tenn. 2019). · cites it 6× “2006) (citing Tenn. Code Ann. § 23-3-105 ); Federal Ins.”
Boyd v. Comdata Network, Inc., 88 S.W.3d 203 (Tenn. Ct. App. 2002). · cites it 2× “Tenn.Code Ann. § 23-3-105 (1994). 9 . Jackson v.”
Smith Cnty. Educ. Ass'n v. Anderson, 676 S.W.2d 328 (Tenn. 1984). · cites it 4× “The first is found in T.C.A. § 23-3-105 which provides as follows: No attorney, solicitor or counselor shall be permitted, in giving testimony against a client, or person who consulted him professionally, to disclose any communication made to him as such by such person, during…”
State v. Buford, 216 S.W.3d 323 (Tenn. 2007). · cites it 6× “Tennessee Code Annotated section 23-3-105 (1994) provides: No attorney, solicitor or counselor shall be permitted, in giving testimony against a client, or person who consulted the attorney, solicitor or counselor professionally, to disclose any communication made to the…”
State ex. rel. Flowers v. Tennessee Trucking Ass'n Self Ins. Grp. Trust, 209 S.W.3d 602 (Tenn. Ct. App. 2006). · cites it 2× “Tenn.Code Ann. § 23-3-105. If it is established that a portion of the requested documents are work product, the burden shifts back to the party requesting discovery to estabhsh that it is nonetheless entitled to the material.”
Commonwealth v. Maguigan, 511 A.2d 1327 (Pa. 1986). · cites it 2× “At that point, contrary to the position that was taken here today and, in fact, taken on the 13th, the District Attorney conceded that there was a legitimate Fifth Amendment issue.”
Hannah Ann Culbertson v. Randall Eric Culbertson, 393 S.W.3d 678 (Tenn. Ct. App. 2012). · cites it 2× “3d at 615 -16 (citing Tenn.Code Ann. § 23-3-105; Federal Ins. Co.”
Woralak Kalyawongsa Udo Liell, Philip P. Durand E. Michael Morris, Attorneys-Appellees v. Margaret Jean Moffett, 105 F.3d 283 (6th Cir. 1997). · cites it 2× “See Tenn.Code Ann. § 23-3-105. On the other hand, if he did represent the plaintiffs as well as the federal government, then the exception to the privilege relied upon by the district court applies.”
Royal Surplus Lines Ins. v. Sofamor Danek Grp., Inc., 190 F.R.D. 463 (W.D. Tenn. 1999). · cites it 2× “Tenn.Code Ann. § 23-3-105 (1994). This statute is an embodiment of the common law principles of the privilege.”
Fed. Ins. Co. v. Arthur Anderson & Co., 816 S.W.2d 328 (Tenn. 1991). · cites it 2× “1 Though presently protected by statute, T.C.A. §§ 23-3-105 to -107, the rule is rooted in the common law of this State.”
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