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

Tenn. Code Ann. § 39-11-614 (2026)

Protection of property

✓ current as of May 2026
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Acts 1989, ch. 591, § 1; 2009, ch. 194, § 1.

Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 2002–2025 · leading case: Howell v. Gonzalez (M.D. Tenn. 2025).
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Howell v. Gonzalez (M.D. Tenn. 2025). · cites it 5× “1998); Tenn. Code Ann. § 39-11-614 . The statutory defense requires a showing not only that the person against whom force was used was trespassing, but also that the force used was immediately necessary to prevent or terminate a trespass.”
State of Tennessee v. Ronnie Brewer (Tenn. Crim. App. 2017). · cites it 3× “§ 39-11-614(a) (2014); see T.P.I.–Crim. 40.”
State of Tennessee v. John Adrian Day (Tenn. Crim. App. 2012). · cites it 3× “Section 39-11-615 provides that “[a] person is justified in threatening or using force against another to protect real or personal property of a third person, if, under the circumstances as the person reasonably believes them to be, the person would be justified under §…”
State of Tennessee v. Timothy L. Morton (Tenn. Crim. App. 2012). · cites it 2× “Tenn. Code Ann. § 39-11-614 (b)(1) & (2) (2008) (emphasis added).”
State of Tennessee v. Gerald James Wingard (Tenn. Crim. App. 2011). · cites it 2× “See T.C.A. § 39-11-614 (Protection of Property).”
State of Tennessee v. Burn Harris Dockery, Jr. (Tenn. Crim. App. 2005). · cites it 2× “Additionally, “[a] person in lawful possession of real or personal property is justified in threatening or using force against another when and to the degree it is reasonably believed the force is immediately necessary to prevent or terminate the other’s trespass on the land or…”
Matthew Poliak v. James Adcock (Tenn. Ct. App. 2002). · cites it 2× “Poliak with a two-by-four on July 11, 1998. C. DEFENSE OF PROPERTY Property owners may use as much force as is reasonably necessary to prevent another from unlawfully coming onto their property or to remove another who is trespassing on their property.”
State of Tennessee v. Charles Martin, Jr. (Tenn. Crim. App. 2013). · cites it 2× “6 Regarding the assaultive offense while the Defendant was in jail, the Defendant argues that he was authorized to use force to retrieve his medications from the prisoner, citing Tennessee Code Annotated section 39-11-614 (protection of property).”
State of Tennessee v. Antwon Thomas (Tenn. Crim. App. 2015). · cites it 2× “” In support of his argument, he relies on Tennessee Code Annotated section 39-11-614, which provides for a person‟s reasonable use of force to protect personal property.”
State v. Michael Buell (Tenn. Crim. App. 2010). “§ 38-2-102 , § 39-11-614(a-c). When read in pari m ateria , these two statutes evinc e a cle ar leg islative inten t that d ead ly forc e is no t perm itted in the d efen se of prop erty.”
— Tenn. Code Ann. § 39-11-614(a) — 1 case
State of Tennessee v. Ronnie Brewer (Tenn. Crim. App. 2017). “§ 39-11-614(a) (2014); see T.P.I.–Crim. 40.”
— Tenn. Code Ann. § 39-11-614(c) — 1 case
State of Tennessee v. Ronnie Brewer (Tenn. Crim. App. 2017). “§ 39-11-614(a) (2014); see T.P.I.–Crim. 40.”
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.