Tennessee Code Annotated
Tenn. Code Ann. § 28-3-109 (2026)
Rent - Official misconduct - Contracts not otherwise covered - Title insurance - Demand notes
✓ current as of May 2026
- (a) The following actions shall be commenced within six (6) years after the cause of action accrued:
- (1) Actions for the use and occupation of land and for rent;
- (2) Actions against the sureties of guardians, executors and administrators, sheriffs, clerks, and other public officers, for nonfeasance, misfeasance, and malfeasance in office; and
- (3) Actions on contracts not otherwise expressly provided for.
- (b) The cause of action on title insurance policies, guaranteeing title to real estate, shall accrue on the date the loss or damage insured or guaranteed against is sustained.
- (c) The cause of action on demand notes shall be commenced within ten (10) years after the cause of action accrued.
Code 1858, § 2775 (deriv. Acts 1715, ch. 27, § 5); Shan., § 4472; Code 1932, § 8600; Acts 1947, ch. 126, § 1; C. Supp. 1950, § 8600; Acts 1976, ch. 472, § 1; modified; T.C.A. (orig. ed.), § 28-309.
Notes of Decisions
Cited in 203
cases (31 in the last 5 years), 1981–2025 · leading case: Individual Healthcare Specialists, Inc. v. Bluecross Blueshield of Tennessee, Inc., 566 S.W.3d 671 (Tenn. 2019).
Individual Healthcare Specialists, Inc. v. Bluecross Blueshield of Tennessee, Inc., 566 S.W.3d 671 (Tenn. 2019). “The statute of limitations for breach-of-contract actions is six years, see Tenn. Code Ann. § 28-3-109 (a)(3) (2017), and the statute of limitations for unjust enrichment (as asserted in this lawsuit) and conversion is three years, see Tenn.”
House v. Est. of Edmondson, 245 S.W.3d 372 (Tenn. 2008). “Alternatively, the plaintiff argues that McLaren should have broadened the scope of his investigation by covering a six-year period under Tennessee Code Annotated section 28-3-109 (2000), the limitations period applicable to breach of contract actions.”
Brenda Benz-Elliott v. Barrett Enter., LP, 456 S.W.3d 140 (Tenn. 2015). “Thus, given the basis of the legal claim and the type of injury sustained, the Alexander Court concluded that the six-year statute of limitations for contracts provided in Tennessee Code Annotated section 28-3-109 applied. Id. at 800. In so holding, the Alexander Court…”
Dean Witter Reynolds, Inc. v. McCoy, 853 F. Supp. 1023 (E.D. Tenn. 1994). “Tenn.Code Ann. § 28-3-109(a) provides in part: “The following actions shall be commenced within six (6) years after the cause of action accrued: .”
Franklin Am. Mortg. Co. v. Univ. Nat'l Bank of Lawrence, 910 F.3d 270 (6th Cir. 2018). “FAMC concedes that Tennessee has not addressed this precise 2Although Tennessee law applies to the Agreement generally and has a longer six-year statute of limitations, see Tenn. Code Ann. § 28-3-109 (a), UNB argues that the Kansas statute of limitations, Kan.”
Tigg v. Pirelli Tire Corp., 232 S.W.3d 28 (Tenn. 2007). “Tenn.Code Ann. § 28-3-109(a)(3) (2000). Claims for interference with contract have a statute of limitations of three years.”
Wilson v. Harris, 304 S.W.3d 824 (Tenn. Ct. App. 2009). “The operative language in the order of dismissal is: “The Motion to Dismiss as filed by the Defendants is GRANTED, as the statute of limitations, as set forth in Tenn. Code Ann. § 28-3-109 , has run, and bars a suit on the alleged debt.”
Pera v. Kroger Co., 674 S.W.2d 715 (Tenn. 1984). “" T.C.A. § 28-3-109(3). The only authority cited by the Court of Appeals was the case of McCombs v.”
Wright v. Wright, 832 S.W.2d 542 (Tenn. Ct. App. 1991). “Although the appellants contend this case presents six issues on appeal, we perceive there to be only three dispositive issues for consideration: (1) whether the contract was still in effect at the time of Mr.”
Nationwide Mut. Fire Ins. Co. v. Memphis Light, Gas, & Water, 578 S.W.3d 26 (Tenn. Ct. App. 2018). “§ 28-3-105 (providing that actions for injuries to real property shall be commenced within three years of the accruing of the cause of action); Tenn. Code Ann. § 28-3-109 (providing that actions on contracts not otherwise provided for shall be commenced within six years after…”
Munson Hardisty, LLC v. Legacy Pointe Apts., LLC, 359 F. Supp. 3d 546 (E.D. Tenn. 2019). “Both parties agree that plaintiff's contract-related claims are governed by Tenn. Code Ann. § 28-3-109 (a)(3), which instructs "actions on contracts not otherwise expressly provided for" must be commenced within six years after the cause of action accrues.”
Oceanics Schs., Inc. v. Barbour, 112 S.W.3d 135 (Tenn. Ct. App. 2003). “4 In so holding, the trial court rejected Barbour’s argument that the plaintiffs suit is subject to the six-year period of limitations set forth in Tenn.Code Ann. § 28-3-109 (2000) and/or the three-year statute of limitations found at Tenn.”
— Tenn. Code Ann. § 28-3-109(1) — 1 case
Levine v. March, 266 S.W.3d 426 (Tenn. Ct. App. 2007).
— Tenn. Code Ann. § 28-3-109(3) — 7 cases
Pera v. Kroger Co., 674 S.W.2d 715 (Tenn. 1984). “" T.C.A. § 28-3-109(3). The only authority cited by the Court of Appeals was the case of McCombs v.”
Am. Fid. Fire Ins. Co. v. Tucker, 671 S.W.2d 837 (Tenn. Ct. App. 1983).
Town of Smyrna v. Ridley, 730 S.W.2d 318 (Tenn. 1987).
Finova Capital Corp. v. Regel, 195 S.W.3d 656 (Tenn. Ct. App. 2005).
Rosiles-Perez v. Superior Forestry Serv., Inc., 250 F.R.D. 332 (M.D. Tenn. 2008).
— Tenn. Code Ann. § 28-3-109(a) — 6 cases
Sparks v. Metro. Gov't of Nashville Cnty., 771 S.W.2d 430 (Tenn. Ct. App. 1989).
Dean Witter Reynolds, Inc. v. McCoy, 853 F. Supp. 1023 (E.D. Tenn. 1994). “Tenn.Code Ann. § 28-3-109(a) provides in part: “The following actions shall be commenced within six (6) years after the cause of action accrued: .”
Kirby Parkway Prof'l Condo. Ass'n, Inc. v. Cindy-Jarvis Ltd., L.P. (Tenn. Ct. App. 2020).
The Edward Jackson Younger Fam. Irrevocable Trust, by & Through Angela Tracy Younger, Tr. v. Evelyn W. Ross, Personally & Individually & as Settlor of the Evelyn W. Ross Irrevocable Life Ins. Trust (Tenn. Ct. App. 2025).
Robert W. Mills v. Nita D. Mills (Tenn. Ct. App. 2015).
— Tenn. Code Ann. § 28-3-109(a)(1) — 2 cases
Networks USA X, Inc. v. Nationwide Mut. Ins., 748 F. Supp. 2d 836 (E.D. Tenn. 2010).
Susan Green v. Leon Moore (Tenn. Ct. App. 2001).
— Tenn. Code Ann. § 28-3-109(a)(3) — 65 cases
Individual Healthcare Specialists, Inc. v. Bluecross Blueshield of Tennessee, Inc., 566 S.W.3d 671 (Tenn. 2019). “The statute of limitations for breach-of-contract actions is six years, see Tenn. Code Ann. § 28-3-109 (a)(3) (2017), and the statute of limitations for unjust enrichment (as asserted in this lawsuit) and conversion is three years, see Tenn.”
Brenda Benz-Elliott v. Barrett Enter., LP, 456 S.W.3d 140 (Tenn. 2015). “Thus, given the basis of the legal claim and the type of injury sustained, the Alexander Court concluded that the six-year statute of limitations for contracts provided in Tennessee Code Annotated section 28-3-109 applied. Id. at 800. In so holding, the Alexander Court…”
Dean Witter Reynolds, Inc. v. McCoy, 853 F. Supp. 1023 (E.D. Tenn. 1994). “Tenn.Code Ann. § 28-3-109(a) provides in part: “The following actions shall be commenced within six (6) years after the cause of action accrued: .”
Tigg v. Pirelli Tire Corp., 232 S.W.3d 28 (Tenn. 2007). “Tenn.Code Ann. § 28-3-109(a)(3) (2000). Claims for interference with contract have a statute of limitations of three years.”
Wright v. Wright, 832 S.W.2d 542 (Tenn. Ct. App. 1991). “Although the appellants contend this case presents six issues on appeal, we perceive there to be only three dispositive issues for consideration: (1) whether the contract was still in effect at the time of Mr.”
— Tenn. Code Ann. § 28-3-109(a)(3)(2000) — 1 case
Linus Thornton v. James A. Massey (Tenn. Ct. App. 2007).
— Tenn. Code Ann. § 28-3-109(c) — 3 cases
Keller v. Colgems-EMI Music, Inc., 924 S.W.2d 357 (Tenn. Ct. App. 1996).
C.A. Hobbs, Jr., Inc. v. David Brainard, Susan B. Reyes, & Carol B. Ham, 919 S.W.2d 337 (Tenn. Ct. App. 1995).
Hinman v. ValleyCrest Landscaping Dev., Inc. (M.D. Tenn. 2020).
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