Tenn. Code Ann. » Tenn. Code / Title 39 / Chapter 11 / Part 6
Tennessee Code Annotated

Tenn. Code Ann. § 39-11-604 (2026)

Reckless injury of innocent third person

✓ current as of May 2026
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Even though a person is justified under this part in threatening or using force or deadly force against another, the justification afforded by this part is unavailable in a prosecution for harm to an innocent third person who is recklessly injured or recklessly killed by the use of such force.

Acts 1989, ch. 591, § 1.

Notes of Decisions
Cited in 6 cases (3 in the last 5 years), 2014–2025 · leading case: State v. Betts, 514 P.3d 341 (Kan. 2022).
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State v. Betts, 514 P.3d 341 (Kan. 2022). “"); Tenn. Code Ann. § 39-11-604 (self-defense justification "unavailable in a prosecution for harm to an innocent third person who is recklessly injured or recklessly killed by the use of such force"); Tex.”
Timothy McKinney v. State of Tennessee (Tenn. Crim. App. 2025). · cites it 13× “At the pretrial conference, the State said that the Defendant was not entitled to a self-defense instruction pursuant to Tennessee Code Annotated section 39-11-604, which prevents a defendant from raising self-defense in a prosecution for reckless harm to a third person.”
Jeremy Jarvis v. State of Tennessee (Tenn. Crim. App. 2014). · cites it 8× “Counsel admitted that his notes concerning the case did not include reference to Tennessee Code Annotated section 39-11-604, which precludes the use of self-defense as a defense when the use of force recklessly injures or kills an innocent third party, and that he was pursuing a…”
State of Tennessee v. Mohamed A. Almahmmody (Tenn. Crim. App. 2019). · cites it 4× “See Tenn. Code Ann. § 39-11-604 (2015). Defendant’s requested instruction would remove culpability if his action was “unintentional.”
State of Tennessee v. Antoine Perrier (2017). · cites it 2× “See Tenn. Code Ann. § 39-11-604 (2014 & 2017 Supp.”
Commonwealth v. Kenneth Jose Santana-Rodriguez (Mass. 2025). “17-A, § 101(3); Tenn. Code Ann. § 39-11-604 ; Tex. Penal Code Ann.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.