Tennessee Code Annotated

Tenn. Code Ann. § 41-24-110 (2026)

Powers and duties not delegable to contractor

✓ current as of May 2026
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No contract for correctional services shall authorize, allow or imply a delegation of the authority or responsibility of the commissioner to a prison contractor for any of the following:

Acts 1986, ch. 932, § 10.


Notes of Decisions
Cited in 27 cases, 1997–2016 · leading case: Mandela v. Campbell, 978 S.W.2d 531 (Tenn. 1998).
Mandela v. Campbell, 978 S.W.2d 531 (Tenn. 1998). · cites it 6× “Accordingly, we must decide whether the TDOC’s Uniform Disciplinary Procedures violate Tenn. Code Ann. § 41-24-110 (5) by permitting private contractor employees to sit on disciplinary boards.”
Richardson v. McKnight, 521 U.S. 399 (1997). “Given a continual and conceded need for deterring constitutional violations and our sense that the firm's tasks are not enormously different in respect to their importance from various other publicly important tasks carried out by private firms, we are not persuaded that the…”
Sandy Eugene Womack v. Corr. Corp. Of Am. D/B/A Whiteville Corr. Facility, 448 S.W.3d 362 (Tenn. 2014). · cites it 2× “3 (citing Tenn.Code Ann. § 41-24-110(5) (1997)). Thus, "all punishments for disciplinary infractions other than verbal warnings imposed by employees of private prison operators must be approved by the Commissioner's designee.”
Friedmann v. Corr. Corp. of Am., 310 S.W.3d 366 (Tenn. Ct. App. 2009). · cites it 3× “Tenn.Code Ann. § 41-24-110 provides that: Powers and duties not delegable to contractor.”
Turner v. Campbell, 15 S.W.3d 466 (Tenn. Ct. App. 1999). · cites it 4× “Section 41-24-110(5). Thus, the Commissioner of Corrections has formulated a policy to govern the imposition of punishment for violating prison rules in a privately operated prison.”
Irwin v. Tennessee Dep't of Corr., 244 S.W.3d 832 (Tenn. Ct. App. 2007). · cites it 2× “T.C.A. § 41-24-110(5). TDOC’s Uniform Disciplinary Procedures, therefore, "mandate appointment of a liaison between the TDOC and the private contractor.”
Winslow Watson v. Tennessee Dep't of Corr., Tennessee Bd. of Paroles, CCA, & Jody Benjamin, 970 S.W.2d 494 (Tenn. Ct. App. 1998). “That T.C.A. 41-24-110, 41-24-109 as it relates to contractors for correctional services be declared unconstitutional.”
Jeffery Walton v. Tennessee Dep't of Corr. (Tenn. Ct. App. 2016). · cites it 12× “Tenn. Code Ann. § 41-24-110 (emphasis added).”
George Campbell, Jr. v. Tennessee Dep't of Corr. (Tenn. Ct. App. 2010). · cites it 4× “3 Under Tennessee Code Annotated § 41-24-110, a contract for correctional services may not delegate the authority of the TDOC Commissioner to take disciplinary actions against inmates.”
Alex Friedmann v. Corr. Corp. of Am. (Tenn. Ct. App. 2009). · cites it 4× “Tenn. Code Ann. § 41-24-110 provides that: Powers and duties not delegable to contractor.”
Alexander Baxter v. Dept. of Corr. (Tenn. Ct. App. 2001). · cites it 4× “” Baxter argues further that, by not following its own procedures requiring a “commissioner’s designee” to observe all Class B disciplinary hearings, TDOC violated the Private Prison Contracting Act, Tenn. Code Ann. § 41-24-101 et seq. (1997), which prohibits delegating inmate…”
Wilson v. So. Centr. Corr. Facility Disciplinary Bd (Tenn. Ct. App. 2000). · cites it 6× “The suits were consolidated in the Tennessee Supreme Court, which concluded that so long as the commissioner’s designee retained the ultimate power to approve or modify the recommendations of the panel, the final authority over discipline still rested with TDOC, and its…”
— Tenn. Code Ann. § 41-24-110(5) — 12 cases
Mandela v. Campbell, 978 S.W.2d 531 (Tenn. 1998). “Accordingly, we must decide whether the TDOC’s Uniform Disciplinary Procedures violate Tenn. Code Ann. § 41-24-110 (5) by permitting private contractor employees to sit on disciplinary boards.”
Sandy Eugene Womack v. Corr. Corp. Of Am. D/B/A Whiteville Corr. Facility, 448 S.W.3d 362 (Tenn. 2014). “3 (citing Tenn.Code Ann. § 41-24-110(5) (1997)). Thus, "all punishments for disciplinary infractions other than verbal warnings imposed by employees of private prison operators must be approved by the Commissioner's designee.”
Turner v. Campbell, 15 S.W.3d 466 (Tenn. Ct. App. 1999). “Section 41-24-110(5). Thus, the Commissioner of Corrections has formulated a policy to govern the imposition of punishment for violating prison rules in a privately operated prison.”
Irwin v. Tennessee Dep't of Corr., 244 S.W.3d 832 (Tenn. Ct. App. 2007). “T.C.A. § 41-24-110(5). TDOC’s Uniform Disciplinary Procedures, therefore, "mandate appointment of a liaison between the TDOC and the private contractor.”
Jeffery Walton v. Tennessee Dep't of Corr. (Tenn. Ct. App. 2016). “Tenn. Code Ann. § 41-24-110 (emphasis added).”
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