Tennessee Code Annotated

Tenn. Code Ann. § 36-3-610 (2026)

Violation of order or consent agreement - Civil or criminal contempt - Financial penalty

✓ current as of May 2026

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(a) Upon violation of the order of protection or a court-approved consent agreement, the court may hold the defendant in civil or criminal contempt and punish the defendant in accordance with the law. A judge of the general sessions court shall have the same power as a court of record to punish the defendant for contempt when exercising jurisdiction pursuant to this part or when exercising concurrent jurisdiction with a court of record. A judge of the general sessions court who is not a licensed attorney shall appoint an attorney referee to hear charges of criminal contempt.

(b)
- (1) In addition to the authorized punishments for contempt of court, the judge may assess any person who violates an order of protection or a court-approved consent agreement a civil penalty of fifty dollars ($50.00). The judge may further order that any support payment made pursuant to an order of protection or a court-approved consent agreement be made under an income assignment to the clerk of court.
- (2) The judge upon finding a violation of an order of protection or a court-approved consent order shall require a bond of the respondent until such time as the order of protection expires. Such bond shall not be less than two thousand five hundred dollars ($2,500) and shall be payable upon forfeit as provided. Bond shall be set at whatever the court determines is necessary to reasonably assure the safety of the petitioner as required. Any respondent for whom bond has been set may deposit with the clerk of the court before which the proceeding is pending a sum of money in cash equal to the amount of the bond. The clerk of the court may deposit funds received in lieu of bonds, or any funds received from the forfeiture of bonds, in an interest bearing account. Any interest received from such accounts shall be payable to the office of the clerk. Failure to comply with this subsection (b) may be punished by the court as a contempt of court as provided in title 29, chapter 9.
- (3) If a respondent posting bond under this subsection (b) does not comply with the conditions of the bond, the court having jurisdiction shall enter an order declaring the bond to be forfeited. Notice of the order of forfeiture shall be mailed forthwith by the clerk to the respondent at the respondent's last known address. If the respondent does not within thirty (30) days from the date of the forfeiture satisfy the court that compliance with the conditions of the bond was met, the court shall enter judgment for the state against the defendant for the amount of the bond and costs of the court proceedings. The judgment and costs may be enforced and collected in the same manner as a judgment entered in a civil action.
- (4) Nothing in this section shall be construed to limit or affect any remedy in effect on July 1, 2010.

(c) Upon collecting the civil penalty imposed by subsection (b), the clerk shall, on a monthly basis, send the money to the state treasurer who shall deposit it in the domestic violence community education fund created by § 36-3-616.

(d) The proceeds of a judgment for the amount of the bond pursuant to this section shall be paid quarterly to the administrative office of the courts. The quarterly payments shall be due on the fifteenth day of the fourth month of the year; the fifteenth day of the sixth month; the fifteenth day of the ninth month; and on the fifteenth day of the first month of the next succeeding year. The proceeds shall be allocated equally on an annual basis as follows:
- (1) To provide legal representation to low-income Tennesseans in civil matters in such manner as determined by the supreme court as described in § 16-3-808(c); provided, that one-fourth (¼) of such funds shall be allocated to an appropriate statewide nonprofit organization capable of providing continuing legal education, technology support, planning assistance, resource development and other support to organizations delivering civil legal representation to indigents. The remainder shall be distributed to organizations delivering direct assistance to clients with Legal Services Corporation funding as referenced in the Tennessee State Plan for Civil Legal Justice approved in March, 2001, by the Legal Services Corporation;
- (2) To the domestic violence state coordinating council, created by title 38, chapter 12;
- (3) To the Tennessee Court Appointed Special Advocates Association (CASA); and
- (4) To Childhelp.

Acts 1979, ch. 350, § 12; T.C.A., § 36-1212; Acts 1989, ch. 297, § 1; 1994, ch. 858, § 1; 1995, ch. 127, § 1; 2010 , ch. 1094, §§ 1, 2.

Notes of Decisions

Cited in 15 cases (1 in the last 5 years), 1997–2024 · leading case: Cable v. Clemmons, 36 S.W.3d 39 (Tenn. 2001).

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Cable v. Clemmons, 36 S.W.3d 39 (Tenn. 2001). · cites it 4× “” Tenn. Code Ann. § 36-3-610 (a) (1996). The statutes also provide that the failure to attend counseling sessions as directed in an order of protection “may be punished as criminal or civil contempt.”

Jacqueline G. Furlong v. Kevin Keane Furlong, 370 S.W.3d 329 (Tenn. Ct. App. 2011). · cites it 2× “Courts are informed by Tenn.Code Ann. § 36-3-610(a)(2010), that they may hold a person who violates an order of protection “in civil or criminal contempt and punish the defendant in accordance with the law.”

State v. Winningham, 958 S.W.2d 740 (Tenn. 1997). · cites it 3× “The trial court imposed punishment for both civil contempt and criminal contempt, pursuant to Tenn.Code Ann. §§ 36-3-610 (1991) and 29-9-105 (1980).”

State v. Gray, 46 S.W.3d 749 (Tenn. Ct. App. 2000). · cites it 4× “Tenn.Code Ann. § 36-3-610(a) gives the general sessions court the power to enforce the order of the circuit court.”

Stephanie Nichole Lee v. Christopher Cornell Eskridge (Tenn. Ct. App. 2016). · cites it 7× “E2014-02555-COA-R3-CV-FILED-FEBRUARY 26, 2016 The trial court, upon finding that Christopher Cornell Eskridge (Respondent) repeatedly violated orders of protection issued to protect Stephanie Nicole Lee (Petitioner), sentenced him to ten days in jail and required him to post a…”

Toniann Whitaker v. James B. Devereaux (Tenn. Ct. App. 2018). · cites it 6× “See Tenn. Code Ann. § 36-3-610 (b)(2). Following a hearing on August 14, 2017, the trial court entered an order resolving some of Ms.”

Kisha Dean Trezevant v. Stanley H. Trezevant, III (Tenn. Ct. App. 2024). · cites it 6× “8 (citing Tenn. Code Ann. § 36-3-610 (a)).7 The Tennessee Supreme Court went on to explain that “conduct qualifying as contempt under these provisions constitutes a violation of the general criminal laws[.”

State of Tennessee v. Karen Ann Matthews (Tenn. Crim. App. 2011). · cites it 6× “§ 36-3-610(a) (“Upon violation of the order of protection or a court-approved consent agreement, the court may hold the defendant in civil or criminal contempt and punish the defendant in accordance with the law.”

State of Tennessee v. Scotty Henry Pace, Jr. (Tenn. Ct. App. 2007). · cites it 2× “” Tenn. Code Ann. § 36-3-610 (a) (Supp. 2001).”

State of Tennessee v. Scotty Henry Pace, Jr. (Tenn. Ct. App. 2006). · cites it 2× “Pace appeals contending the evidence insufficient to sustain a finding of guilt.2 A court may hold a defendant in criminal contempt, and punish the defendant accordingly, upon a finding the defendant violated an order of protection or a court-approved consent agreement.”

Anna Lois Long v. Sammy Lee Brown (Tenn. Ct. App. 2014). · cites it 2× “We further hold that the trial court’s order should also be modified to include “the statement of the maximum penalty that may be imposed pursuant to § 36-3-610 for violating [the] order” as required by Tenn.”

Show all 15 citing cases →

— Tenn. Code Ann. § 36-3-610(2) — 1 case

Stephanie Nichole Lee v. Christopher Cornell Eskridge (Tenn. Ct. App. 2016). “E2014-02555-COA-R3-CV-FILED-FEBRUARY 26, 2016 The trial court, upon finding that Christopher Cornell Eskridge (Respondent) repeatedly violated orders of protection issued to protect Stephanie Nicole Lee (Petitioner), sentenced him to ten days in jail and required him to post a…”

— Tenn. Code Ann. § 36-3-610(a) — 5 cases

State v. Gray, 46 S.W.3d 749 (Tenn. Ct. App. 2000). “Tenn.Code Ann. § 36-3-610(a) gives the general sessions court the power to enforce the order of the circuit court.”

Cable v. Clemmons, 36 S.W.3d 39 (Tenn. 2001). “” Tenn. Code Ann. § 36-3-610 (a) (1996). The statutes also provide that the failure to attend counseling sessions as directed in an order of protection “may be punished as criminal or civil contempt.”

Kisha Dean Trezevant v. Stanley H. Trezevant, III (Tenn. Ct. App. 2024). “8 (citing Tenn. Code Ann. § 36-3-610 (a)).7 The Tennessee Supreme Court went on to explain that “conduct qualifying as contempt under these provisions constitutes a violation of the general criminal laws[.”

State of Tennessee v. Karen Ann Matthews (Tenn. Crim. App. 2011). “§ 36-3-610(a) (“Upon violation of the order of protection or a court-approved consent agreement, the court may hold the defendant in civil or criminal contempt and punish the defendant in accordance with the law.”

State of Tennessee v. Elder Mark Anthony Thornton (Tenn. Crim. App. 2013).

— Tenn. Code Ann. § 36-3-610(a)(2010) — 1 case

Jacqueline G. Furlong v. Kevin Keane Furlong, 370 S.W.3d 329 (Tenn. Ct. App. 2011). “Courts are informed by Tenn.Code Ann. § 36-3-610(a)(2010), that they may hold a person who violates an order of protection “in civil or criminal contempt and punish the defendant in accordance with the law.”

— Tenn. Code Ann. § 36-3-610(b) — 3 cases

Toniann Whitaker v. James B. Devereaux (Tenn. Ct. App. 2018). “See Tenn. Code Ann. § 36-3-610 (b)(2). Following a hearing on August 14, 2017, the trial court entered an order resolving some of Ms.”

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