Tennessee Code Annotated

Tenn. Code Ann. § 33-6-104 (2026)

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✓ current as of May 2026
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Acts 2000, ch. 947, § 1; 2001, ch. 377, § 3; 2002, ch. 730, § 31; 2010 , ch. 633, § 1.


Notes of Decisions
Cited in 14 cases, 1987–2015 · leading case: State v. Groves, 735 S.W.2d 843 (Tenn. Crim. App. 1987).
State v. Groves, 735 S.W.2d 843 (Tenn. Crim. App. 1987). · cites it 9× “Involuntary commitment under T.C.A. § 33-6-104 is civil in nature and thus, our standard of review is de novo upon the record of the trial court with a presumption of the correctness of the finding, unless the preponderance of the evidence is otherwise.”
State v. Phillips, 968 S.W.2d 874 (Tenn. Crim. App. 1996). · cites it 11× “3 After the diagnosis and evaluation peri *879 od, if certification is made that the acquittee is committable under the civil involuntary care and treatment standards provided in T.C.A § 33-6-104, the district attorney general must file a complaint in criminal court seeking both…”
State v. Blackstock, 19 S.W.3d 200 (Tenn. 2000). “A person may be “judicially committed to involuntary care and treatment,” if the following are found: 1) the person is mentally retarded; 2) the person poses a substantial likelihood of serious harm as defined in § 33-6-104(e) because of the mental retardation; 3) the person…”
Mercer v. HCA Health Servs. of Tennessee, Inc., 87 S.W.3d 500 (Tenn. Ct. App. 2002). “§ 33-6-104 shall be discharged” if “he no longer meets the standards under which the admission took place, AND the patient’s detention is not otherwise authorized under the admission statute.”
State v. Tripp, 754 S.W.2d 92 (Tenn. Crim. App. 1988). · cites it 2× “This remission was effected by maintaining a schedule of medication in the closely supervised environment of MTMHI and without such supervision the patient would pose a likelihood of serious harm to others as contemplated in T.C.A. § 33-6-104(a). The court expressed the further…”
State v. Overbay, 874 S.W.2d 645 (Tenn. Crim. App. 1993). “§ 33-7-303 and § 33-6-104, the court will judicially commit this defendant.”
Williams v. Shelby Cnty. Health Care Corp., 803 F. Supp. 1306 (W.D. Tenn. 1992). · cites it 3× “the person poses an immediate substantial likelihood of serious harm, as defined in § 33-6-104, because of the mental illness, THEN .”
State of Tennessee v. Janice Floyd (Tenn. Crim. App. 2001). · cites it 7× “Finally, the letter from Western Mental Health Institute indicated that the defendant did not meet the standards for judicial commitment pursuant to Tennessee Code Annotated section§ 33-6-104 and 7-303. On April 27, 2000, the matter came before the trial court.”
State of Tennessee v. Jackie H. Martin (Tenn. Crim. App. 2008). · cites it 4× “The appellant continued to meet the commitment standards imposed by Tenn. Code Ann. § 33-6-104 (1994 Supp.) and § 33-7-303(c) (1994 Supp.”
State v. Blackstock (Tenn. Crim. App. 2010). · cites it 3× “In the petition, the defendant claimed that he needed care, training or treatment and that the failure to provide a secure facility would create a likelihood of causing serious harm, as defined under T.C.A. § 33-6-104, because of his mental retardation.”
Billy Hembree v. State (Tenn. Ct. App. 2001). · cites it 2× “After this finding, Peavyhouse was subjected to an involuntary commitment proceeding in which MTMHI physicians testified that he was subject to involuntary commitment in accordance with Tennessee Code Annotated section 33-6-104. Following this hearing, the Circuit Court for…”
State of Tennessee v. Kenneth Ryan Mallady (Tenn. Crim. App. 2015). · cites it 2× “1987) (applying this standard to involuntary commitment pursuant to Tennessee Code Annotated section 33-6-104). This standard has been interpreted to mean that the appellate court will affirm the trial court’s decision “unless an error of law affecting the result has been…”
— Tenn. Code Ann. § 33-6-104(a) — 4 cases
State v. Groves, 735 S.W.2d 843 (Tenn. Crim. App. 1987). “Involuntary commitment under T.C.A. § 33-6-104 is civil in nature and thus, our standard of review is de novo upon the record of the trial court with a presumption of the correctness of the finding, unless the preponderance of the evidence is otherwise.”
State v. Tripp, 754 S.W.2d 92 (Tenn. Crim. App. 1988). “This remission was effected by maintaining a schedule of medication in the closely supervised environment of MTMHI and without such supervision the patient would pose a likelihood of serious harm to others as contemplated in T.C.A. § 33-6-104(a). The court expressed the further…”
State v. Phillips, 968 S.W.2d 874 (Tenn. Crim. App. 1996). “3 After the diagnosis and evaluation peri *879 od, if certification is made that the acquittee is committable under the civil involuntary care and treatment standards provided in T.C.A § 33-6-104, the district attorney general must file a complaint in criminal court seeking both…”
State v. Blackstock (Tenn. Crim. App. 2010). “In the petition, the defendant claimed that he needed care, training or treatment and that the failure to provide a secure facility would create a likelihood of causing serious harm, as defined under T.C.A. § 33-6-104, because of his mental retardation.”
— Tenn. Code Ann. § 33-6-104(b) — 2 cases
State v. Groves, 735 S.W.2d 843 (Tenn. Crim. App. 1987). “Involuntary commitment under T.C.A. § 33-6-104 is civil in nature and thus, our standard of review is de novo upon the record of the trial court with a presumption of the correctness of the finding, unless the preponderance of the evidence is otherwise.”
State of Tennessee v. Janice Floyd (Tenn. Crim. App. 2001). “Finally, the letter from Western Mental Health Institute indicated that the defendant did not meet the standards for judicial commitment pursuant to Tennessee Code Annotated section§ 33-6-104 and 7-303. On April 27, 2000, the matter came before the trial court.”
— Tenn. Code Ann. § 33-6-104(c) — 1 case
State of Tennessee v. Janice Floyd (Tenn. Crim. App. 2001). “Finally, the letter from Western Mental Health Institute indicated that the defendant did not meet the standards for judicial commitment pursuant to Tennessee Code Annotated section§ 33-6-104 and 7-303. On April 27, 2000, the matter came before the trial court.”
— Tenn. Code Ann. § 33-6-104(e) — 1 case
State v. Blackstock, 19 S.W.3d 200 (Tenn. 2000). “A person may be “judicially committed to involuntary care and treatment,” if the following are found: 1) the person is mentally retarded; 2) the person poses a substantial likelihood of serious harm as defined in § 33-6-104(e) because of the mental retardation; 3) the person…”
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