Tennessee Code Annotated
Tenn. Code Ann. § 28-1-109 (2026)
Suspension during injunction
✓ current as of May 2026 Cite as: Tenn. Code Ann. § 28-1-109 (2026)
When the commencement of an action is stayed by injunction, the time of the continuance of the injunction is not to be counted.
Code 1858, § 2756; Shan., § 4447; Code 1932, § 8573; T.C.A. (orig. ed.), § 28-110.
Notes of Decisions
Cited in 8
cases (2 in the last 5 years), 2005–2024 · leading case: Norman Redwing v. Catholic Bishop for the Diocese of Memphis
Norman Redwing v. Catholic Bishop for the Diocese of Memphis (2012)
“Tenn.Code Ann. § 28-1-106 (Supp.2011). 17 .”
First Volunteer Bank v. FMM Bushnell, LLC (2021)
“§ 362 enjoined Bushnell from taking any action to enforce its lien on real property securing the Union Planters DOT, as modified, the duration the injunction is added to any statute of limitation regarding enforcement of the Union Planters DOT, as modified, pursuant to Tenn.…”
Robert L. McCullough, Jr. v. Carla Vaughn (2017)
“Plaintiffs appeal contending their claims are not time barred because the defendant filed her bankruptcy petition prior to the commencement of this action and Tenn. Code Ann. § 28-1-109 expressly states, “When the commencement of an action is stayed by injunction, the time of…”
Collins v. Tennessee Department of Revenue (2016)
“Application of T.C.A. § 28-1-109 to the TDOR To resolve the statute of limitations and tolling question, the Court must interpret a web of Tennessee and federal law.”
Zurich American Insurance Company v. Scott, Murphy & Daniel, LLC (2024)
“SMD argues that Tennessee Code Annotated § 28-1-109, a statute providing that “[w]hen the commencement of an action is stayed by injunction, the time of the continuance of the injunction is not to be counted,” does so.”
Michael Collins v. Tenn. Dep't of Revenue (2019)
“Dep’t of Revenue also entitled to the benefit of the tolling provision ( Tenn. Code Ann. § 28-1-109 ). We conclude, however, that the statutory tolling provision does not apply to actions by the State.”
Edward Rabbit v. Daniel L. Mills (2005)
“By extending the proper time in which to revive the judgment until May 9, 2004, the court found that the Rabbitts timely filed their petition for writ of scire facias on January 30, 2004.”
Rachel L. Bell v. Michael Gardner (2018)
“” Tenn. Code Ann. § 28-1-109 (2017). But the court held the statute was inapplicable because Ms.”
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