Tennessee Code Annotated

Tenn. Code Ann. § 39-14-101 (2026)

Consolidation of theft offenses

✓ current as of May 2026
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Conduct denominated as theft in this part constitutes a single offense embracing the separate offenses referenced before 1989 as embezzlement, false pretense, fraudulent conversion, larceny, receiving or concealing stolen property, and other similar offenses.

Acts 1989, ch. 591, § 1.


Notes of Decisions
Cited in 40 cases (4 in the last 5 years), 1995–2026 · leading case: State v. Gentry, 538 S.W.3d 413 (Tenn. 2017).
State v. Gentry, 538 S.W.3d 413 (Tenn. 2017). · cites it 9× “" Tenn. Code Ann. § 39-14-101 (2014 & 2017 Supp.”
State v. Brewer, 932 S.W.2d 1 (Tenn. Crim. App. 1996). · cites it 2× “Sentencing Commission Comments to Tenn.Code Ann. § 39-14-101. 22 . The rules regarding the appellate examination of the sufficiency of the evidence which supports a guilty verdict were presented in the discussion of the previous issue and for the sake of brevity shall not be…”
Nijhawan v. Holder, 557 U.S. 29 (2009). “, Tenn. Code Ann. §§39-14-101 , 39-14-105, 39-14-118, 39-14-133 (1991).”
State v. James, 315 S.W.3d 440 (Tenn. 2010). “§ 39-14-101 (2006), and “theft of property” was defined in terms of knowingly obtaining or exercising control over property without the owner’s consent and with the intent to deprive the owner of the property.”
State of Tennessee v. Perry A. March, 293 S.W.3d 576 (Tenn. Crim. App. 2008). · cites it 2× “§ 39-14-101, - 103. As such, theft, including offenses formerly theorized as embezzlement, fraudulent conversion, and the like, may be committed generically in essentially one or two ways: (1) taking or obtaining property or (2) merely exercising control over the property, all…”
State of Iowa v. Betty Ann Nall, 894 N.W.2d 514 (Iowa 2017). “); Tenn. Code Ann. § 39-14-101 (West, Westlaw current through 2017 1st Reg.”
State v. Kennedy, 7 S.W.3d 58 (Tenn. Crim. App. 1999). · cites it 2× “” See Tenn.Code Ann. § 39-14-101 (emphasis added).”
State v. Grissom, 956 S.W.2d 514 (Tenn. Crim. App. 1997). · cites it 2× “While Bilbrey would lend support to a similar argument for the former crime of embezzlement, the legislature has consolidated all of the theft offenses into one single offense, Tennessee Code Annotated Section 39-14-101 (1991), defining theft as knowingly obtaining or exercising…”
State v. Gene Ivan Amanns, 2 S.W.3d 241 (Tenn. Crim. App. 1999). · cites it 2× “See Tenn.Code Ann. § 39-14-101 (1991). For purposes of instructing the jury, the heretofore existing complexities and historical distinctions among theft and theft-related offenses are of no significance as the jury is charged upon the offense of theft.”
State v. Byrd, 968 S.W.2d 290 (Tenn. 1998). · cites it 2× “See Tenn.Code Ann. § 39-14-101 (stating current theft statute “embraces .”
Black & Decker (US), Inc. v. Smith, 568 F. Supp. 2d 929 (W.D. Tenn. 2008). “§ 39-3-901 (repealed in 1989 and replaced by §§ 39-14-101 et seq., which consolidated various theft offenses such as embezzlement, false pretense, fraudulent conversion, and larceny, into a single statute); Rafferty v.”
State v. Young, 904 S.W.2d 603 (Tenn. Crim. App. 1995). · cites it 2× “He contends that this proposition is clearly supported by the language in Tennessee Code Annotated section 39-14-101: Conduct denominated as theft in this part constitutes a single offense embracing the separate offenses heretofore known as: embezzlement, false pretense,…”
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