Tennessee Code Annotated
Tenn. Code Ann. § 34-1-121 (2026)
Powers of court - Additional actions - Waiver of requirements - Compromise
✓ current as of May 2026
- (a) The court has broad discretion to require additional actions not specified in this chapter, and chapters 2 and 3 of this title as the court deems in the best interests of the minor or person with a disability and the property of the minor or the person with a disability. The court also has discretion to waive requirements specified in this chapter, and chapters 2 and 3 of this title if the court finds it is in the best interests of the minor or person with a disability to waive such requirements, particularly in those instances where strict compliance would be too costly or place an undue burden on the fiduciary or the minor or the person with a disability.
- (b) In any action, claim, or suit in which a person with a disability is a party or in any case of personal injury to a person with a disability caused by the alleged wrongful act of another, the court in which the action, claim, or suit is pending, or the court supervising the fiduciary relationship if a fiduciary has been appointed, has the power to approve and confirm a compromise of the matters in controversy on behalf of the person with a disability. If the court deems the compromise to be in the best interest of the person with a disability, any order or decree approving and confirming the compromise shall be binding on the person with a disability.
- (c) A tort claim settlement involving a minor does not require court approval except as required by § 29-34-105(a).
Amended by 2022 Tenn. Acts, ch. 917, Secs.s2, s3 eff. 4/27/2022.
Amended by 2013 Tenn. Acts, ch. 435, s 40, eff. 7/1/2013.
Acts 1992, ch. 794, § 22; 1994, ch. 855, § 12; 2000, ch. 610, § 1; T.C.A. § 34-11-121.
Notes of Decisions
Cited in 17
cases (3 in the last 5 years), 2003–2026 · leading case: Crystal BLACKWELL, as Next Friend to Jacob Blackwell, a Minor v. SKY HIGH SPORTS NASHVILLE OPERATIONS, LLC, 523 S.W.3d 624 (Tenn. Ct. App. 2017).
Crystal BLACKWELL, as Next Friend to Jacob Blackwell, a Minor v. SKY HIGH SPORTS NASHVILLE OPERATIONS, LLC, 523 S.W.3d 624 (Tenn. Ct. App. 2017). “Tenn. Code Ann. § 34-1-121 (b); see also Vannucci v.”
In Re Conservatorship of Groves, 109 S.W.3d 317 (Tenn. Ct. App. 2003). “Trial courts should be extremely hesitant to use their prerogative under Tenn.Code Ann. § 34-1-121(a) to excuse guardians ad litem from any of their statutory responsibilities.”
Watkins Ex Rel. Watkins v. Bailey, 484 F. App'x 18 (6th Cir. 2012). “” See Tenn. Code Ann. § 34-1-121 (b). In other words, there was “judicial acceptance” of the prior inconsistent position.”
In re The Conservatorship of Cody Lee Wade, 484 S.W.3d 151 (Tenn. Ct. App. 2015). “In their petition, the Wades asserted that, under Tennessee Code Annotated § 34-1-121, the trial court had broad authority to approve the SNT.”
In Re Conservatorship of John Bruce Wilson, Jr. (Tenn. Ct. App. 2022). “, abused its discretion by approving, pursuant to his authority -5- under Tennessee Code Annotated § 34-1-121, a mediated settlement agreement.”
Diane v. Vannucci v. Memphis Obstetrics & Gynecological Ass'n P.C. & Diana v. Vannucci v. W.B. Moss (Tenn. Ct. App. 2006). “Pursuant to section 34-1-121 of the Tennessee Code, the settling parties petitioned the trial court to approve the settlement.”
In Re Conservatorship of Betty A. Winston (Tenn. Ct. App. 2026). “” Tenn. Code Ann. § 34-1-121 (a). Thus, there are two classes of expenses at issue in this case: (1) expenses for the benefit and protection of Ward, which may be approved after the fact; and (2) compensation to Appellant as conservator, which must have prior court approval.”
In Re: Conservatorship of Lila M. Trout (Tenn. Ct. App. 2009). “Tenn. Code Ann. § 34-1-121 (a) (2007) (emphasis added).”
Derrick Hussey v. Michael Woods, 538 S.W.3d 476 (2017). “Tenn. Code Ann. § 34-1-121 (b) (2015); see also id.”
In Re Est. of Billy Joe Stricklan (Tenn. Ct. App. 2010). “5 Tenn. Code Ann. § 34-1-121 (b) provides that [i]n any action, claim, or suit in which a minor .”
In Re Conservatorship of John Martin Muldoon (Tenn. Ct. App. 2020). “E2019-01621-COA-R3-CV ___________________________________ This appeal arises from a petition to appoint a conservator under Tennessee Code Annotated section 34-1-121. The petitioner/wife was originally appointed as conservator of respondent/husband in October 2018.”
In Re: Conservatorship of Michael Thomas Jones & Timothy Alan Jones Beverly Anne Jones v. Kevin Thomas Jones (Tenn. Ct. App. 2004). “Tenn. Code Ann. § 34-1-121 (a) (2001). In addition, the courts in Kilby, Day, and Mora indicated, albeit in dicta, that a conservator in a conservatorship proceeding “would have the authority to seek a decree requiring the parents to contribute” to the support of the adult…”
— Tenn. Code Ann. § 34-1-121(a) — 1 case
In Re Conservatorship of Groves, 109 S.W.3d 317 (Tenn. Ct. App. 2003). “Trial courts should be extremely hesitant to use their prerogative under Tenn.Code Ann. § 34-1-121(a) to excuse guardians ad litem from any of their statutory responsibilities.”
— Tenn. Code Ann. § 34-1-121(b) — 3 cases
Watkins Ex Rel. Watkins v. Bailey, 484 F. App'x 18 (6th Cir. 2012). “” See Tenn. Code Ann. § 34-1-121 (b). In other words, there was “judicial acceptance” of the prior inconsistent position.”
Diane v. Vannucci v. Memphis Obstetrics & Gynecological Ass'n P.C. & Diana v. Vannucci v. W.B. Moss (Tenn. Ct. App. 2006). “Pursuant to section 34-1-121 of the Tennessee Code, the settling parties petitioned the trial court to approve the settlement.”
In Re Conservatorship of John Bruce Wilson, Jr. (Tenn. Ct. App. 2022). “, abused its discretion by approving, pursuant to his authority -5- under Tennessee Code Annotated § 34-1-121, a mediated settlement agreement.”
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