Tennessee Code Annotated
Tenn. Code Ann. § 29-11-104 (2026)
Enforcement of contribution - Procedure - Limitation
✓ current as of May 2026
- (a) Whether or not judgment has been entered in an action against two (2) or more tortfeasors for the same injury or wrongful death, contribution may be enforced by separate action in the circuit or chancery courts to be tried according to the forms of chancery.
- (b) Where a judgment has been entered in an action against two (2) or more tortfeasors for the same injury or wrongful death, contribution may be enforced in that action by judgment in favor of one against other judgment defendants by motion upon notice to all parties to the action; provided that, any issue as to indemnity may be determined at the hearing of such motion.
- (c) If there is a judgment for the injury or wrongful death against the tortfeasor seeking contribution, any separate action by the tortfeasor to enforce contribution must be commenced within one (1) year after satisfaction of the judgment.
- (d) If there is no judgment for the injury or wrongful death against the tortfeasor seeking contribution, the tortfeasor's right of contribution is barred unless the tortfeasor has either:
- (1) Discharged by payment the common liability within the statute of limitations period applicable to claimant's right of action against the tortfeasor and has commenced tortfeasor's action for contribution within one (1) year after payment; or
- (2) Agreed while action is pending against the tortfeasor to discharge the common liability and has within one (1) year after the agreement paid the liability and commenced tortfeasor's action for contribution within one (1) year of payment.
- (e) The recovery of a judgment for an injury or wrongful death against one (1) tortfeasor does not of itself discharge the other tortfeasors from liability for the injury or wrongful death unless the judgment is satisfied. The satisfaction of the judgment does not impair any right of contribution.
- (f) The judgment of a court in determining the liability of the several defendants to a claimant for an injury or wrongful death after trial on the merits shall be binding among such defendants in determining their right to contribution or indemnity, except where a claimant commenced an action for injury or wrongful death prior to April 3, 1968.
Acts 1968, ch. 575, § 4; T.C.A., § 23-3104.
Notes of Decisions
Cited in 4
cases (1 in the last 5 years), 1982–2026 · leading case: Owens v. Truckstops of Am., 915 S.W.2d 420 (Tenn. 1996).
Owens v. Truckstops of Am., 915 S.W.2d 420 (Tenn. 1996). “Tenn. Code Ann. § 29-11-104 (1980). If the plaintiff's cause of action had accrued after the decision in McIntyre and after the effective date of Tenn.”
Manning v. Fort Deposit Bank, 619 F. Supp. 1327 (W.D. Tenn. 1985). “Finally, the UCATA provides for a one year statute of limitations on actions for contribution, commencing on the date of satisfaction of judgment on the common liability against the party seeking contribution or, if no judgment exists, commencing on the date of payment to the…”
Great West Cas. Co. v. Fletcher, 287 S.E.2d 429 (N.C. Ct. App. 1982). “This seems necessary in view of the position some courts have taken that adjudication of liability to the plaintiff of several defendants is not necessarily res adjudicata of the liability for determination of contribution claims.”
Kars LLC v. Ronald Ogle (Tenn. Ct. App. 2026). “Finally, they argue that the “one satisfaction rule is still good law in Tennessee” and has been codified at Tennessee Code Annotated section 29-11-104(e). Section 29-11-104(e) provides that “[t]he recovery of a judgment for an injury or wrongful death against one (1) tortfeasor…”
— Tenn. Code Ann. § 29-11-104(c) — 1 case
Manning v. Fort Deposit Bank, 619 F. Supp. 1327 (W.D. Tenn. 1985). “Finally, the UCATA provides for a one year statute of limitations on actions for contribution, commencing on the date of satisfaction of judgment on the common liability against the party seeking contribution or, if no judgment exists, commencing on the date of payment to the…”
— Tenn. Code Ann. § 29-11-104(e) — 1 case
Kars LLC v. Ronald Ogle (Tenn. Ct. App. 2026). “Finally, they argue that the “one satisfaction rule is still good law in Tennessee” and has been codified at Tennessee Code Annotated section 29-11-104(e). Section 29-11-104(e) provides that “[t]he recovery of a judgment for an injury or wrongful death against one (1) tortfeasor…”
— Tenn. Code Ann. § 29-11-104(f) — 1 case
Great West Cas. Co. v. Fletcher, 287 S.E.2d 429 (N.C. Ct. App. 1982). “This seems necessary in view of the position some courts have taken that adjudication of liability to the plaintiff of several defendants is not necessarily res adjudicata of the liability for determination of contribution claims.”
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