Tennessee Code Annotated

Tenn. Code Ann. § 24-1-206 (2026)

Clergy - Communications confidential - Waiver - Misdemeanor offense

✓ current as of May 2026
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Acts 1959, ch. 24, §§ 1-5; impl. am. Acts 1971, ch. 162, § 3; T.C.A., §§ 24-109 -- 24-111; modified; Acts 1989, ch. 591, § 113.


Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1987–2022 · leading case: State v. Reid, 164 S.W.3d 286 (Tenn. 2005).
State v. Reid, 164 S.W.3d 286 (Tenn. 2005). · cites it 4× “See Tenn. Code Ann. § 24-1-206 (2000). Similarly, the record shows that the defense called Mary Ann Hea during the competency hearing to testify about her numerous interviews with the defendant as a social worker for the public defender.”
Smith v. Smith, 102 S.W.3d 648 (Tenn. Ct. App. 2002). · cites it 2× “The Trial Court read a portion of Tenn.Code Ann. § 24-1-206 to allow Reverend Griffin to determine if his answers fell within the parameters of such confidences.”
Vermilye v. State, 754 S.W.2d 82 (Tenn. Crim. App. 1987). · cites it 2× “The privilege created by T.C.A. § 24-1-206 is for the protection of the person communicating the information to the minister, not the minister.”
In Re Grand Jury Investigation. Appeal of United States of Am., 918 F.2d 374 (3rd Cir. 1990). “§§ 19-13-16 — 19-13-18 (1990); Tenn.Code Ann. § 24-1-206 (1990); Utah Code Ann.”
State v. Boling, 806 S.W.2d 202 (Tenn. Crim. App. 1990). “The pertinent statute, Tennessee Code Annotated, § 24-1-206, provides as follows: (a)(1) No minister of the gospel, no priest of the Catholic Church, no rector of the Episcopal Church, no ordained rabbi, and no regular minister of religion of any religious organization or…”
John F. Pinkard, M.D. v. HCA Health Servs. of Tennessee, Inc. D/B/A Summit Med. Ctr., 545 S.W.3d 443 (2017). “§ 24-7-114 , the news reporter’s privilege, Tenn. Code Ann. § 24-1-208 , and the clergy-penitent privilege, Tenn.”
Jackson v. Futrell (Tenn. Ct. App. 2000). · cites it 7× “Jackson also takes issue with the trial court’s decision to explain the operation of the clergy-penitent privilege in Tenn. Code Ann. § 24-1-206 (Supp. 1999) to the Reverend Moore.”
State of Tennessee v. Deon Lamont Cartmell (Tenn. Crim. App. 2014). · cites it 4× “-26- The Defendant sought to prevent the State’s witnesses from referring to his statements to Chaplain Duke because they were privileged pursuant to Code section 24-1-206. The State responded that the Defendant did not attend church where the chaplain was the minister, did not…”
State of Tennessee v. Billy Jason Hancock (Tenn. Crim. App. 2014). · cites it 4× “Code section 24-1-206 provides, in pertinent part, as follows: No minister of the gospel, priest of the Catholic Church, rector of the Episcopal Church, ordained rabbi, or regular minister of religion of any religious organization or denomination usually referred to as a church,…”
Mahan v. Mahan (Tenn. Ct. App. 2000). · cites it 6× “Through its enactment of Tenn. Code Ann. § 24-1-206 , our legislature has stated very clearly that communications between individuals and their clergy merit protection from disclosure.”
Megan Arndts Woody v. Jeremy Brice Woody (Tenn. Ct. App. 2022). · cites it 2× “According to Mother, after 4 See Tenn. Code Ann. § 24-1-206 (explaining that clergy members shall not be required to disclose confidential information during testimony).”
State of Tennessee v. Jeremy Curtis Workman (Tenn. Crim. App. 2011). · cites it 2× “T.C.A. § 24-1-206(a)(1) (2009). There are, however, exceptions to this privilege; specifically, an exception to the privilege exists in child sexual abuse cases: The privileged quality of communication between husband and wife and between any professional person and the…”
— Tenn. Code Ann. § 24-1-206(a)(1) — 3 cases
State of Tennessee v. Jeremy Curtis Workman (Tenn. Crim. App. 2011). “T.C.A. § 24-1-206(a)(1) (2009). There are, however, exceptions to this privilege; specifically, an exception to the privilege exists in child sexual abuse cases: The privileged quality of communication between husband and wife and between any professional person and the…”
State of Tennessee v. Deon Lamont Cartmell (Tenn. Crim. App. 2014). “-26- The Defendant sought to prevent the State’s witnesses from referring to his statements to Chaplain Duke because they were privileged pursuant to Code section 24-1-206. The State responded that the Defendant did not attend church where the chaplain was the minister, did not…”
State of Tennessee v. Billy Jason Hancock (Tenn. Crim. App. 2014). “Code section 24-1-206 provides, in pertinent part, as follows: No minister of the gospel, priest of the Catholic Church, rector of the Episcopal Church, ordained rabbi, or regular minister of religion of any religious organization or denomination usually referred to as a church,…”
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