Tenn. Code Ann. » Tenn. Code / Title 40 / Chapter 20 / Part 1
Tennessee Code Annotated

Tenn. Code Ann. § 40-20-111 (2026)

Concurrent or cumulative sentences

✓ current as of May 2026
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Code 1858, § 5228; Shan., § 7201; Acts 1919, ch. 115, § 1; Code 1932, § 11764; Acts 1979, ch. 227, § 1; T.C.A. (orig. ed.), § 40-2711.

Notes of Decisions
Cited in 197 cases (14 in the last 5 years), 1983–2025 · leading case: Summers v. State, 212 S.W.3d 251 (Tenn. 2007).
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Summers v. State, 212 S.W.3d 251 (Tenn. 2007). · cites it 4× “He assert *257 ed that the judgments imposing concurrent sentences were void as they directly contravened Tennessee Code Annotated section 40-20-111(b) 4 and Tennessee Rule of Criminal Procedure 32(c)(3)(C).”
Benson v. State, 153 S.W.3d 27 (Tenn. 2005). · cites it 6× “Therefore, pointing to Tennessee Code Annotated section 40-20-111(b) (2003) and Tennessee Rule of Criminal Procedure 32, the petitioner argues that the trial court was required to impose consecutive rather than concurrent sentences.”
State v. Alder, 71 S.W.3d 299 (Tenn. Crim. App. 2001). · cites it 4× “Tenn.Code Ann. § 40-20-111(b) (1997). Under these provisions, consecutive sentencing is mandatory when a defendant commits a felony while on bail and the defendant is subsequently convicted of both offenses.”
State v. Langston, 708 S.W.2d 830 (Tenn. 1986). · cites it 8× “Under T.C.A., § 40-20-111(b), it was mandatory that the sentence for the robbery be thus made consecutive to the other sentences because the defendant had been released on bail one day prior to the commission of the robbery and was on bail at the time the robbery was committed.”
State v. Taylor, 739 S.W.2d 227 (Tenn. 1987). · cites it 4× “T.C.A. § 40-20-111. The decision of whether the prison terms are to be consecutive or concurrent is left to the discretion of the trial court.”
McLaney v. Bell, 59 S.W.3d 90 (Tenn. 2001). · cites it 2× “McLaney presents three issues for review: (1) whether the record shows that his arrest occurred while he was on bail for a felony offense (thus requiring consecutive sentences pursuant to Tenn.Code Ann. § 40-20-111 (2000) and Tenn.”
State v. Hastings, 25 S.W.3d 178 (Tenn. Crim. App. 1999). · cites it 2× “In addition, Tennessee Code Annotated section 40-20-111(b) provides: In any case in which a defendant commits a felony while such defendant was released on bail .”
State v. Arnold, 824 S.W.2d 176 (Tenn. Crim. App. 1991). · cites it 4× “The statute to which Thompson referred is presently designated T.C.A. § 40-20-111(a) which, in pertinent part, states the following: Concurrent or cumulative sentences.”
United States v. Larry Braswell, 704 F. App'x 528 (6th Cir. 2017). · cites it 2× “and the defendant is convicted of both offenses, the trial judge shall not have the discretion as to whether the sentences shall run concurrently or cumulatively, but shall order that the sentences be served cumulatively.”
State v. Samuel, 243 S.W.3d 592 (Tenn. Crim. App. 2007). “These acts were committed June 8, 2004, and that under Rule 32 the defendant is required to be sentenced to consecutive sentencing, and under T.C.A. 40-20-111 it requires consecutive mandatory sentencing.”
State v. Vasser, 870 S.W.2d 543 (Tenn. Crim. App. 1993). “§ 40-20-111 (regarding concurrent or cumulative sentences, providing that if “any person has been convicted of two (2) or more offenses, judgment shall be rendered on each conviction after the first .”
State v. Cannon, 661 S.W.2d 893 (Tenn. Crim. App. 1983). · cites it 2× “1974); T.C.A. § 40-20-111, formerly § 40-2711. We find that the trial court acted within its discretion in ordering consecutive sentences in this case.”
Show all 197 citing cases →
— Tenn. Code Ann. § 40-20-111(B) — 2 cases
State of Tennessee v. Earl Jerome Lee, Jr. (Tenn. Crim. App. 2020).
Earl Jerome Lee v. Glen Turner, Warden (Tenn. Crim. App. 2006).
— Tenn. Code Ann. § 40-20-111(a) — 15 cases
State v. Arnold, 824 S.W.2d 176 (Tenn. Crim. App. 1991). “The statute to which Thompson referred is presently designated T.C.A. § 40-20-111(a) which, in pertinent part, states the following: Concurrent or cumulative sentences.”
Charles Owens v. Kevin Genovese, Warden (Tenn. Crim. App. 2018).
State of Tennessee v. Terrell L. Lawrence (Tenn. Crim. App. 2019).
Jabari Issa Mandela a/k/a John H. Wooden v. Howard Carlton, Warden (Tenn. Crim. App. 2008).
Jason E. Mize v. State of Tennessee (Tenn. Crim. App. 2005).
— Tenn. Code Ann. § 40-20-111(b) — 120 cases
Summers v. State, 212 S.W.3d 251 (Tenn. 2007). “He assert *257 ed that the judgments imposing concurrent sentences were void as they directly contravened Tennessee Code Annotated section 40-20-111(b) 4 and Tennessee Rule of Criminal Procedure 32(c)(3)(C).”
Benson v. State, 153 S.W.3d 27 (Tenn. 2005). “Therefore, pointing to Tennessee Code Annotated section 40-20-111(b) (2003) and Tennessee Rule of Criminal Procedure 32, the petitioner argues that the trial court was required to impose consecutive rather than concurrent sentences.”
State v. Alder, 71 S.W.3d 299 (Tenn. Crim. App. 2001). “Tenn.Code Ann. § 40-20-111(b) (1997). Under these provisions, consecutive sentencing is mandatory when a defendant commits a felony while on bail and the defendant is subsequently convicted of both offenses.”
State v. Langston, 708 S.W.2d 830 (Tenn. 1986). “Under T.C.A., § 40-20-111(b), it was mandatory that the sentence for the robbery be thus made consecutive to the other sentences because the defendant had been released on bail one day prior to the commission of the robbery and was on bail at the time the robbery was committed.”
State v. Hastings, 25 S.W.3d 178 (Tenn. Crim. App. 1999). “In addition, Tennessee Code Annotated section 40-20-111(b) provides: In any case in which a defendant commits a felony while such defendant was released on bail .”
— Tenn. Code Ann. § 40-20-111(b)(1) — 1 case
Jeffery Odom v. State of Tennessee (Tenn. Crim. App. 2014).
— Tenn. Code Ann. § 40-20-111(d) — 1 case
State of Tennessee v. Greg Smith - Concurring (Tenn. Crim. App. 2004).
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