Tennessee Code Annotated

Tenn. Code Ann. § 41-21-235 (2026)

Sexual abuse treatment program for incarcerated sex offenders

✓ current as of May 2026
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Acts 1985, ch. 478, § 35; 1998, ch. 970, § 1; 2000, ch. 947, § 6; 2010, ch. 1100, § 69; 2012, ch. 575, § 1.


Notes of Decisions
Cited in 8 cases, 1988–2019 · leading case: Brigham v. Lack, 755 S.W.2d 469 (Tenn. Crim. App. 1988).
Brigham v. Lack, 755 S.W.2d 469 (Tenn. Crim. App. 1988). · cites it 6× “See T.C.A. § 41-21-235 (Supp.1986). Although the pleading was styled “Petition for a writ of habeas corpus,” it plainly did not allege grounds for habeas corpus relief.”
Wade v. State, 914 S.W.2d 97 (Tenn. Crim. App. 1995). · cites it 2× “*104 Tennessee Code Annotated Section 41-21-235 (1990) requires that sex offenders complete a sexual abuse treatment program as a prerequisite for parole.”
Wilson v. State, 899 S.W.2d 648 (Tenn. Crim. App. 1994). · cites it 4× “Tennessee Code Annotated section 41-21-235 directs the Department of Correction to develop a sexual abuse treatment program for sex offenders and require successful participation and completion of such program as a requirement for parole by sex offenders.”
South v. Tennessee Bd. of Paroles, 946 S.W.2d 310 (Tenn. Ct. App. 1996). · cites it 2× “The statute, Tenn.Code Ann. § 41-21-235(b) reads as follows: (a) The department of correction, in cooperation with the department of mental health and mental retardation, shall develop a sexual abuse treatment program for sex offenders incarcerated after the program is…”
Frank R. Dalton v. Tennessee Bd. of Paroles - Concurring (Tenn. Ct. App. 1996). · cites it 25× “Even though Tenn. Code Ann. § 41-21-235 (b) (1990) provides that “[s]uccessful participation and completion of such treatment program shall be a requirement of parole from the correctional institutions by such offenders,” Mr.”
Bruce A. Smiley v. State of Tennessee (2019). · cites it 8× “Petitioner challenged what he claimed to be the illegal, arbitrary, and capricious application of Tenn. Code Ann. § 41-21-235 , the Sex Offender Treatment Program (the “SOTP”), contending he is eligible for a parole hearing but will be denied parole because the State of…”
Alan Dale Bailey v. State of Tennessee (Tenn. Crim. App. 2002). · cites it 3× “Section 41-21-235(b), as it applied to the time of the petitioner’s offenses committed on August 26, 1998, provides, “Successful participation and completion of [a sexual abuse treatment program for incarcerated sex offenders] shall be a consideration for parole from a…”
Jerome William Devereaux v. State of Tennessee - Dissenting (Tenn. Crim. App. 2005). · cites it 2× “Without objection, the petitioner testified that his DOC prison counselor told him “that they don’t give parole to sex offenders” and that his completion of the twenty-four month “sex program,” see T.C.A. § 41-21-235, would not matter. The petitioner also testified that he spoke…”
Tenn. Code Ann. § 41-21-235(b): 3 cases
South v. Tennessee Bd. of Paroles, 946 S.W.2d 310 (Tenn. Ct. App. 1996). “The statute, Tenn.Code Ann. § 41-21-235(b) reads as follows: (a) The department of correction, in cooperation with the department of mental health and mental retardation, shall develop a sexual abuse treatment program for sex offenders incarcerated after the program is…”
Alan Dale Bailey v. State of Tennessee (Tenn. Crim. App. 2002). “Section 41-21-235(b), as it applied to the time of the petitioner’s offenses committed on August 26, 1998, provides, “Successful participation and completion of [a sexual abuse treatment program for incarcerated sex offenders] shall be a consideration for parole from a…”
Frank R. Dalton v. Tennessee Bd. of Paroles - Concurring (Tenn. Ct. App. 1996). “Even though Tenn. Code Ann. § 41-21-235 (b) (1990) provides that “[s]uccessful participation and completion of such treatment program shall be a requirement of parole from the correctional institutions by such offenders,” Mr.”
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.