Tennessee Code Annotated

Tenn. Code Ann. § 40-38-103 (2026)

Rights of crime victims - Generally

✓ current as of May 2026
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Amended by 2018 Tenn. Acts, ch. 598, s 3, eff. 7/1/2018.

Amended by 2015 Tenn. Acts, ch. 527, s 1, eff. 7/1/2015.

Acts 1990, ch. 957, § 3; 1993, ch. 527, §§ 3, 9-11; 1996, ch. 709, § 2; 1997 , ch. 509, § 3; 1998, ch. 1037, § 2; 1998, ch. 1049, § 52; 2009 , ch. 176, § 5.


Notes of Decisions
Cited in 20 cases (7 in the last 5 years), 1995–2024 · leading case: State v. Ring, 56 S.W.3d 577 (Tenn. Crim. App. 2001).
State v. Ring, 56 S.W.3d 577 (Tenn. Crim. App. 2001). · cites it 8× “These provisions contain Tennessee Code Annotated section 40-38-103(a)(2), which provides two methods in which victims can exercise the constitutional right conferred on them by Article I, Section 35 of the Tennessee Constitution, and therefore be allowed to participate in the…”
State v. Blackhurst, 70 S.W.3d 88 (Tenn. Crim. App. 2001). · cites it 2× “Under Tennessee Code Annotated section 40-35-209(b) and section 40-38-103(a)(2), the victim, Gardner, had a right to testify and provide impact information for consideration at the sentencing hearing.”
Hawkins v. Case Mgmt. Inc., 165 S.W.3d 296 (Tenn. Ct. App. 2004). · cites it 2× “” T.C.A. § 40-38-103(1X1). Under T.C.A. § 40-38-108, this immunity extends to “the state, a political subdivision of the state, a government employee, or other official or entity.”
State of Tennessee v. Randall Kenneth Reed (Tenn. Crim. App. 2020). · cites it 26× “Pursuant to Code section 40-38-103(c), a trial court may exclude such a photograph, even if relevant to show the “general appearance and condition of the victim while alive,” see Tenn. Code Ann. § 40-38-103 (c), if the court determines that the photograph’s “probative value is…”
Fite v. State, 910 S.W.2d 861 (Tenn. Ct. App. 1995). · cites it 2× “*863 The def/State of Tennessee contrary to T.C.A. § 40-38-103(c), provide such power of its agents of the Government to enter into any contract or plea agreements by written form and oral, in a court of law or etc.”
State of Tennessee v. Glen Allen Donaldson (Tenn. Crim. App. 2020). · cites it 8× “” T.C.A. § 40-38-103(c). The defendant contends that the statute intrudes upon the purview of the judiciary by usurping the trial court’s authority to determine the admissibility of evidence by making life photographs per se relevant and admissible in homicide cases.”
State of Tennessee v. Charles Griffin (Tenn. Crim. App. 2021). · cites it 6× “” T.C.A. § 40-38-103(c); see State v. Glen Allen Donaldson, No.”
State of Tennessee v. Shannon Bruce Foster (Tenn. Crim. App. 2021). · cites it 4× “” T.C.A. § 40-38-103(c) (2019) (emphasis added).”
State of Tennessee v. Tony Markee Mosley (Tenn. Crim. App. 2024). · cites it 4× “Alternatively, the State argues that the trial court did not abuse its discretion because: (1) Tennessee Code Annotated section 40-38-103(c) permitted the admission of the photograph, “assuming the State offered [it] as evidence to show the victim’s appearance before her death”;…”
State of Tennessee v. Kenneth Ray Niles (Tenn. Crim. App. 2024). · cites it 4× “]’” (quoting T.C.A. § 40-38-103(c), Tenn. R. Evid. 403)), perm.”
State v. Robert D. Ring (Tenn. Crim. App. 2000). · cites it 8× “These provisions contain Tennessee Code Annotated section 40-38-103(a)(2), which provides two methods in which victims can exercise the constitutional right conferred on them by Article I, Section 35 of the Tennessee Constitution, and therefore be allowed to participate in the…”
State of Tennessee v. Ronald Yates (Tenn. Crim. App. 2004). · cites it 4× “" Tenn. Code Ann. § 40-38-103 (a)(2). Such testimony is governed by Tennessee Code Annotated section 40-35-209, which provides that "[a]t the sentencing hearing, the court shall afford the parties the opportunity to be heard and present evidence relevant to the sentencing of the…”
— Tenn. Code Ann. § 40-38-103(1X1) — 1 case
Hawkins v. Case Mgmt. Inc., 165 S.W.3d 296 (Tenn. Ct. App. 2004). “” T.C.A. § 40-38-103(1X1). Under T.C.A. § 40-38-108, this immunity extends to “the state, a political subdivision of the state, a government employee, or other official or entity.”
— Tenn. Code Ann. § 40-38-103(a)(2) — 3 cases
State v. Ring, 56 S.W.3d 577 (Tenn. Crim. App. 2001). “These provisions contain Tennessee Code Annotated section 40-38-103(a)(2), which provides two methods in which victims can exercise the constitutional right conferred on them by Article I, Section 35 of the Tennessee Constitution, and therefore be allowed to participate in the…”
State v. Blackhurst, 70 S.W.3d 88 (Tenn. Crim. App. 2001). “Under Tennessee Code Annotated section 40-35-209(b) and section 40-38-103(a)(2), the victim, Gardner, had a right to testify and provide impact information for consideration at the sentencing hearing.”
State v. Robert D. Ring (Tenn. Crim. App. 2000). “These provisions contain Tennessee Code Annotated section 40-38-103(a)(2), which provides two methods in which victims can exercise the constitutional right conferred on them by Article I, Section 35 of the Tennessee Constitution, and therefore be allowed to participate in the…”
— Tenn. Code Ann. § 40-38-103(c) — 10 cases
State of Tennessee v. Randall Kenneth Reed (Tenn. Crim. App. 2020). “Pursuant to Code section 40-38-103(c), a trial court may exclude such a photograph, even if relevant to show the “general appearance and condition of the victim while alive,” see Tenn. Code Ann. § 40-38-103 (c), if the court determines that the photograph’s “probative value is…”
Fite v. State, 910 S.W.2d 861 (Tenn. Ct. App. 1995). “*863 The def/State of Tennessee contrary to T.C.A. § 40-38-103(c), provide such power of its agents of the Government to enter into any contract or plea agreements by written form and oral, in a court of law or etc.”
State of Tennessee v. Glen Allen Donaldson (Tenn. Crim. App. 2020). “” T.C.A. § 40-38-103(c). The defendant contends that the statute intrudes upon the purview of the judiciary by usurping the trial court’s authority to determine the admissibility of evidence by making life photographs per se relevant and admissible in homicide cases.”
State of Tennessee v. Charles Griffin (Tenn. Crim. App. 2021). “” T.C.A. § 40-38-103(c); see State v. Glen Allen Donaldson, No.”
State of Tennessee v. Shannon Bruce Foster (Tenn. Crim. App. 2021). “” T.C.A. § 40-38-103(c) (2019) (emphasis added).”
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