Tennessee Code Annotated
Tenn. Code Ann. § 39-11-103 (2026)
Territorial jurisdiction
✓ current as of May 2026
- (a) Every person, whether an inhabitant of this or any other state or country, is liable to punishment by the laws of this state, for an offense committed in this state, except where it is by law cognizable exclusively in the courts of the United States.
- (b)
- (1) When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in this state in the county in which the offense was consummated, unless otherwise provided by statute.
- (2) It is no defense that the person charged with the offense was outside of this state when the offense was consummated, if the person used:
- (A) An innocent or guilty agent; or
- (B) Other means proceeding directly from the person.
- (c) When the commission of an offense commenced within this state is consummated outside of its boundaries, the offender is liable to punishment in this state in the county where the offense was commenced.
- (d) If one (1) or more elements of an offense are committed in one (1) county and one (1) or more elements in another, the offense may be prosecuted in either county. Offenses committed on the boundary of two (2) or more counties may be prosecuted in either county.
Acts 1989, ch. 591, § 1; 1990, ch. 1000, § 5.
Notes of Decisions
Cited in 30
cases (6 in the last 5 years), 1997–2026 · leading case: State v. Ritchie, 20 S.W.3d 624 (Tenn. 2000).
State v. Ritchie, 20 S.W.3d 624 (Tenn. 2000). “See Tenn.Code Ann. § 39-11-103(a) (1997). 3 .”
Backpage.Com, LLC v. Cooper, 939 F. Supp. 2d 805 (M.D. Tenn. 2013). “They argue the statute should be read in pan materia with the overall jurisdictional provision of the state criminal codes, Tenn. Code Ann. § 39-11-103 , which states that any person who commits or consummates an offense in the state may be held liable under Ten- ■ nessee law.”
State v. Legg, 9 S.W.3d 111 (Tenn. 1999). “We granted the appeal in this case to address whether the State of Tennessee has territorial jurisdiction pursuant to Tennessee Code Annotated section 39-11-103(b)(1) to prosecute a charge of aggravated kidnapping that was commenced in Alabama.”
State of Tennessee v. Shirley Spina, 99 S.W.3d 596 (Tenn. Crim. App. 2002). “See also, Tenn.Code Ann. § 39-11-103(d) (“If one (1) or more elements of an offense are committed in one (1) county and one (1) or more elements in another, the offense may be prosecuted in either county.”
State of Tennessee v. Ronald Matthew Lacy (Tenn. 2026). “Acts 1169 , 1170 (codified at Tenn. Code Ann. § 39-11-103 ).3 2. Section 39-11-103 grants territorial jurisdiction over three categories of offenses: (1) offenses committed in Tennessee, unless exclusively within the jurisdiction of federal courts, Tenn.”
State of Tennessee v. Kelley Hufford (Tenn. Crim. App. 2019). “” Tennessee Code Annotated section 39-11-103 addresses jurisdiction in those cases in which a crime is committed in multiple states: “When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in…”
State of Tennessee v. Jesus Alfonso Castillo (Tenn. Crim. App. 2020). “” T.C.A. § 39-11-103(b)(2). Likewise, “[w]hen the commission of an offense commenced within this state is consummated outside of its boundaries, the offender is liable to punishment in this state in the county where the offense was commenced.”
State of Tennessee v. Hayden Jennings Berkebile (Tenn. Crim. App. 2024). “]” T.C.A. § 39-11-103(b)(1); see also Legg, 9 S.”
State of Tennessee v. Ronald Matthew Lacy (Tenn. Crim. App. 2024). “]” See Tenn. Code Ann. § 39-11-103 (a) (2018). However, the doctrine also recognizes that the state’s “criminal law is of no force and effect beyond its territorial limits.”
State of Tennessee v. Justin Darnay Graves (Tenn. Crim. App. 2026). “18(b); see also Tenn. Code Ann. § 39-11-103 (d). Venue is a question of fact to be determined by the jury, which may “draw reasonable inferences from the evidence” and may make its determination based solely upon circumstantial evidence.”
State of Tennessee v. Audra Lynn Johnson (Tenn. Crim. App. 2006). “The victim subsequently traveled to Clarksville, Tennessee, where he died on May 8, 2004, in a motel room. The autopsy report confirmed that the victim overdosed on Fentanyl and alcohol.”
State of Tennessee v. Justin Darnay Graves -Concur in Part/Dissent in Part (Tenn. Crim. App. 2026). “”); Tenn. Code Ann. § 39-11-103 (d) (same). When considering whether a trial court has venue, then, it is imperative to closely examine the statute setting forth the elements of the charged crime.”
— Tenn. Code Ann. § 39-11-103(a) — 2 cases
State v. Ritchie, 20 S.W.3d 624 (Tenn. 2000). “See Tenn.Code Ann. § 39-11-103(a) (1997). 3 .”
Kevin Anthony Dickson Junior v. State of Tennessee (Tenn. Crim. App. 2016).
— Tenn. Code Ann. § 39-11-103(b) — 1 case
State of Tennessee v. Ronald Matthew Lacy (Tenn. 2026). “Acts 1169 , 1170 (codified at Tenn. Code Ann. § 39-11-103 ).3 2. Section 39-11-103 grants territorial jurisdiction over three categories of offenses: (1) offenses committed in Tennessee, unless exclusively within the jurisdiction of federal courts, Tenn.”
— Tenn. Code Ann. § 39-11-103(b)(1) — 5 cases
State v. Legg, 9 S.W.3d 111 (Tenn. 1999). “We granted the appeal in this case to address whether the State of Tennessee has territorial jurisdiction pursuant to Tennessee Code Annotated section 39-11-103(b)(1) to prosecute a charge of aggravated kidnapping that was commenced in Alabama.”
Richard Williams v. Tony Mays, Warden (Tenn. Crim. App. 2019).
State of Tennessee v. Kelley Hufford (Tenn. Crim. App. 2019). “” Tennessee Code Annotated section 39-11-103 addresses jurisdiction in those cases in which a crime is committed in multiple states: “When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in…”
State of Tennessee v. Hayden Jennings Berkebile (Tenn. Crim. App. 2024). “]” T.C.A. § 39-11-103(b)(1); see also Legg, 9 S.”
State of Tennessee v. Ronald Matthew Lacy (Tenn. 2026). “Acts 1169 , 1170 (codified at Tenn. Code Ann. § 39-11-103 ).3 2. Section 39-11-103 grants territorial jurisdiction over three categories of offenses: (1) offenses committed in Tennessee, unless exclusively within the jurisdiction of federal courts, Tenn.”
— Tenn. Code Ann. § 39-11-103(b)(2) — 3 cases
State of Tennessee v. Kelley Hufford (Tenn. Crim. App. 2019). “” Tennessee Code Annotated section 39-11-103 addresses jurisdiction in those cases in which a crime is committed in multiple states: “When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in…”
State of Tennessee v. Jesus Alfonso Castillo (Tenn. Crim. App. 2020). “” T.C.A. § 39-11-103(b)(2). Likewise, “[w]hen the commission of an offense commenced within this state is consummated outside of its boundaries, the offender is liable to punishment in this state in the county where the offense was commenced.”
State of Tennessee v. Ronald Matthew Lacy (Tenn. 2026). “Acts 1169 , 1170 (codified at Tenn. Code Ann. § 39-11-103 ).3 2. Section 39-11-103 grants territorial jurisdiction over three categories of offenses: (1) offenses committed in Tennessee, unless exclusively within the jurisdiction of federal courts, Tenn.”
— Tenn. Code Ann. § 39-11-103(b)(2)(A) — 1 case
State of Tennessee v. Audra Lynn Johnson (Tenn. Crim. App. 2006). “The victim subsequently traveled to Clarksville, Tennessee, where he died on May 8, 2004, in a motel room. The autopsy report confirmed that the victim overdosed on Fentanyl and alcohol.”
— Tenn. Code Ann. § 39-11-103(b)(2)(B) — 1 case
State of Tennessee v. Hayden Jennings Berkebile (Tenn. Crim. App. 2024). “]” T.C.A. § 39-11-103(b)(1); see also Legg, 9 S.”
— Tenn. Code Ann. § 39-11-103(c) — 4 cases
State of Tennessee v. Kelley Hufford (Tenn. Crim. App. 2019). “” Tennessee Code Annotated section 39-11-103 addresses jurisdiction in those cases in which a crime is committed in multiple states: “When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in…”
State of Tennessee v. William J. Wagner aka William Justin Wagner (Tenn. Crim. App. 2020).
State of Tennessee v. Jesus Alfonso Castillo (Tenn. Crim. App. 2020). “” T.C.A. § 39-11-103(b)(2). Likewise, “[w]hen the commission of an offense commenced within this state is consummated outside of its boundaries, the offender is liable to punishment in this state in the county where the offense was commenced.”
State of Tennessee v. Ronald Matthew Lacy (Tenn. 2026). “Acts 1169 , 1170 (codified at Tenn. Code Ann. § 39-11-103 ).3 2. Section 39-11-103 grants territorial jurisdiction over three categories of offenses: (1) offenses committed in Tennessee, unless exclusively within the jurisdiction of federal courts, Tenn.”
— Tenn. Code Ann. § 39-11-103(d) — 4 cases
State of Tennessee v. Shirley Spina, 99 S.W.3d 596 (Tenn. Crim. App. 2002). “See also, Tenn.Code Ann. § 39-11-103(d) (“If one (1) or more elements of an offense are committed in one (1) county and one (1) or more elements in another, the offense may be prosecuted in either county.”
State of Tennessee v. Kelley Hufford (Tenn. Crim. App. 2019). “” Tennessee Code Annotated section 39-11-103 addresses jurisdiction in those cases in which a crime is committed in multiple states: “When an offense is commenced outside of this state and consummated in this state, the person committing the offense is liable for punishment in…”
State of Tennessee v. Jesus Alfonso Castillo (Tenn. Crim. App. 2020). “” T.C.A. § 39-11-103(b)(2). Likewise, “[w]hen the commission of an offense commenced within this state is consummated outside of its boundaries, the offender is liable to punishment in this state in the county where the offense was commenced.”
State of Tennessee v. Stacy McKinley Taylor alias Ronald Lee Taylor (Tenn. Crim. App. 2004).
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