Tennessee Code Annotated
Tenn. Code Ann. § 39-14-104 (2026)
Theft of services
✓ current as of May 2026
- (a) A person commits theft of services who:
- (1) Intentionally obtains services by deception, fraud, coercion, forgery, false statement, false pretense or any other means to avoid payment for the services;
- (2) Having control over the disposition of services to others, knowingly diverts those services to the person's own benefit or to the benefit of another not entitled thereto; or
- (3) Knowingly absconds from establishments where compensation for services is ordinarily paid immediately upon the rendering of them, including, but not limited to, hotels, motels and restaurants, without payment or a bona fide offer to pay.
- (b) Any individual directly or indirectly harmed by a violation of subsection (a) shall have legal standing to report such violations to law enforcement and testify in support of corresponding criminal charges.
Acts 1989, ch. 591, § 1; 2011, ch. 348, § 2.
Notes of Decisions
Cited in 20
cases (4 in the last 5 years), 1998–2025 · leading case: State v. Marshall, 319 S.W.3d 558 (Tenn. 2010).
State v. Marshall, 319 S.W.3d 558 (Tenn. 2010). “Three tenants of the Gallatin Housing Authority were indicted under the theft of services statute, Tenn.Code Ann. § 39-14-104, for failing to report to the housing authority earnings that would have increased their rent.”
State v. Cattone, 968 S.W.2d 277 (Tenn. 1998). “We granted an appeal in this case to determine whether the values of service rendered by different individuals may be aggregated under the theft of services statute, Tenn. Code Ann. § 39-14-104 . In State v.”
State v. Gentry, 538 S.W.3d 413 (Tenn. 2017). “, Tenn. Code Ann. § 39-14-104 (2014 & 2017 Supp.”
DirecTV, Inc. v. McCool, 339 F. Supp. 2d 1025 (M.D. Tenn. 2004). “§ 39-13-601 (Count III); under Tennessee theft of services statutes, Tenn.Code Ann. §§ 39-14-104, 7-59-109 (Count IV); under 18 U.”
State v. Watkins, 362 S.W.3d 530 (Tenn. 2012). “§ 39-14-149(c) (2010) ("If conduct that violates this section [a]lso constitutes a violation of § 39-14-104 relative to theft of services, that conduct may be prosecuted under either, but not both, statutes as provided in § 39-11-109.”
Yarboro Sallee v. Tennessee Bd. of Prof'l Responsibility, 469 S.W.3d 18 (Tenn. 2015). “If I do not hear from you today before end of business, you can respond by e-mail to ac[c]ept my offer of a meeting, I will be proceeding to charge your clients with felony violations of TCA 39-14-104(1). Sincerely, Yarbi *26 Attorney Sallee’s saber-rattling emails apparently…”
State of Tennessee v. Alkita M. Odom, 64 S.W.3d 370 (Tenn. Crim. App. 2001). “§ 39-14-104. Clearly, an essential element of both theft of property and theft of services is the receipt of property or services.”
DirecTV, Inc. v. Wallace, 347 F. Supp. 2d 559 (M.D. Tenn. 2004). “§ 39-13-601 (Count III); under Tennessee theft of services statutes, Tenn.Code Ann. §§ 39-14-104, 7-59-109 (Count IV); and under Tennessee common law for conversion (Count VI).”
State of Tennessee v. Brijesh Mukesh Desai (Tenn. Crim. App. 2019). “See Tenn. Code Ann. § 39-14-104 (2014). Defendant relies on State v.”
Kimberly Holliday v. State of Tennessee (Tenn. Crim. App. 2012). “2010), held that “services” under Tennessee Code Annotated Section 39- 11-106(35) does not include a leasehold interest, her “failure to report earnings to the housing authority does not support a conviction under Tenn. Code Ann. § 39-14-104 .” At the hearing on her petition for…”
State of Tennessee v. Anthony Eugene Barnett (Tenn. Crim. App. 2024). “OPINION On June 30, 2022, the defendant was charged with one count of theft of services valued at $1,000 or less pursuant to Tennessee Code Annotated section 39-14-104 and with two counts of vandalism valued at $1,000 or less pursuant to Code section 39-14- 408.”
Rimon Abdou v. Wesley Ben Clark (Tenn. Ct. App. 2024). “-8- In Count III of his amended complaint, Mr.”
— Tenn. Code Ann. § 39-14-104(1) — 2 cases
Yarboro Sallee v. Tennessee Bd. of Prof'l Responsibility, 469 S.W.3d 18 (Tenn. 2015). “If I do not hear from you today before end of business, you can respond by e-mail to ac[c]ept my offer of a meeting, I will be proceeding to charge your clients with felony violations of TCA 39-14-104(1). Sincerely, Yarbi *26 Attorney Sallee’s saber-rattling emails apparently…”
State v. Cattone, 968 S.W.2d 277 (Tenn. 1998). “We granted an appeal in this case to determine whether the values of service rendered by different individuals may be aggregated under the theft of services statute, Tenn. Code Ann. § 39-14-104 . In State v.”
— Tenn. Code Ann. § 39-14-104(a) — 1 case
State of Tennessee v. Brijesh Mukesh Desai (Tenn. Crim. App. 2019). “See Tenn. Code Ann. § 39-14-104 (2014). Defendant relies on State v.”
— Tenn. Code Ann. § 39-14-104(b) — 1 case
State of Tennessee v. Brijesh Mukesh Desai (Tenn. Crim. App. 2019). “See Tenn. Code Ann. § 39-14-104 (2014). Defendant relies on State v.”
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