Tennessee Code Annotated

Tenn. Code Ann. § 49-5-409 (2026)

Continuation of service unless notice of dismissal or failure of reelection sent

✓ current as of May 2026
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Amended by 2022 Tenn. Acts, ch. 678, s 1, eff. 3/28/2022.

Amended by 2021 Tenn. Acts, ch. 378, Secs.s1, s2, s3 eff. 5/11/2021.

Amended by 2015 Tenn. Acts, ch. 232, s 1, eff. 7/1/2015.

Acts 1943, ch. 147, § 1; C. Supp. 1950, § 2340.1; Acts 1971, ch. 49, §§ 1, 2; 1974, ch. 654, §§ 64, 65; 1977, ch. 455, § 1; 1981, ch. 186, § 1; T.C.A. (orig. ed.), § 49-1306; Acts 1992, ch. 535, § 25; 2000, ch. 569, § 1; 2002, ch. 586, § 1; 2010 , ch. 798, §§ 1, 2; 2011 , ch. 70, §§ 2, 3; 2011 , ch. 255, § 1.


Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1988–2022 · leading case: Arnwine v. Union Cnty. Bd. of Educ., 120 S.W.3d 804 (Tenn. 2003).
Arnwine v. Union Cnty. Bd. of Educ., 120 S.W.3d 804 (Tenn. 2003). · cites it 2× “Tennessee Code Annotated section 49-5-409(b)(2) (1996 & Supp.2000) provides that teachers who are dismissed or not reelected must receive notice prior to April 15 to be applicable to the next succeeding school year.”
Ray v. Bd. of Educ., 72 S.W.3d 657 (Tenn. Ct. App. 2001). · cites it 6× “Neither Defendants' nor Plaintiff's motion for partial summary judgment addressed Plaintiff's remaining claim against Defendants for breach of continuing contract under Tenn. Code Ann. § 49-5-409 . . Tenn.Code Ann.”
State ex rel. McGhee v. John, 837 S.W.2d 596 (Tenn. 1992). · cites it 4× “T.C.A. § 49-5-409 provides for the method of terminating teacher’s contracts and makes the specific exception in subsection (b)(2) that the Board of Education may transfer any teacher from one position to another at its option, subject to securing any rights accrued or accruable…”
Reed v. Washington Cnty. Bd. of Educ., 756 S.W.2d 250 (Tenn. 1988). · cites it 2× “Brothers, supra, the teacher completed the probationary period, and was employed for an additional year beyond the probationary period because the school board failed to comply with the requirements for termination of a teacher established by the Teachers’ Continuing Contract…”
Preston Barbee v. Union City Bd. of Educ., 559 F. App'x 450 (6th Cir. 2014). · cites it 2× “§ 49-2-301(b)(1)(J). “It is the duty of the board of education to assign [this recommendation duty] to its director of schools[.”
Malone v. Shelby Cnty. Bd. of Educ., 773 S.W.2d 256 (Tenn. Ct. App. 1989). · cites it 2× “Section 49-5-409 provides: (a) Teachers in service and under control of the public elementary and high schools of Tennessee continue in such service until they have received written notice, from their Board of Education, of their dismissal or failure of re-election.”
Candice Mosby v. Fayette Cnty. Bd. of Educ. (Tenn. Ct. App. 2020). · cites it 40× “§ 49-1-302 (d)(2)(A) that a teacher’s evaluation “shall be a factor” in all employment-related decisions, may a non-tenured teacher maintain an action challenging her nonrenewal under Tenn. Code Ann. § 49-5-409 when the director of schools makes the decision to non-renew without…”
Pamela Dallas v. Shelby Cnty. Bd. of Educ. (Tenn. Ct. App. 2019). · cites it 39× “Tenn. Code Ann. § 49-5-409 (2014).12 The trial court denied Ms.”
Lacy McAllister v. Lawrence Cnty. Sch. Sys. Bd. of Educations (Tenn. Ct. App. 2022). · cites it 16× “” Tenn. Code Ann. § 49-5-409 (a). -2- documents reflecting alleged observations of Teacher.”
Hayes v. Metro. Gov't of Nashville & Davidson Cnty., Tennessee, The (M.D. Tenn. 2021). · cites it 10× “However, in that regard, there is also no dispute that Leffler received verbal notice on April 29, 2020 and written notice on or around May 4, 2020 that “her job as Executive Director was being eliminated effective June 30, 2020” (Doc.”
Garcia v. The Metro. Gov't of Nashville & Davidson Cnty., Tennessee (M.D. Tenn. 2019). · cites it 6× “” Tenn. Code Ann. § 49-5-409 (a). See Dallas v.”
Cannon Cnty. Bd. of Educ. v. Goldy Wade & Cannon Cnty. Educ. Ass'n (Tenn. Ct. App. 2008). · cites it 7× “Wade was notified by the Board of the non-renewal of his contract prior to April 15, 2002 in compliance with the Continuing Contract Law, Tenn. Code Ann. § 49-5-409 (b)(2). Wade and the CCEA then filed a grievance pursuant to the locally negotiated agreement (sometimes called…”
— Tenn. Code Ann. § 49-5-409(a) — 2 cases
Preston Barbee v. Union City Bd. of Educ., 559 F. App'x 450 (6th Cir. 2014). “§ 49-2-301(b)(1)(J). “It is the duty of the board of education to assign [this recommendation duty] to its director of schools[.”
Ray v. Bd. of Educ., 72 S.W.3d 657 (Tenn. Ct. App. 2001). “Neither Defendants' nor Plaintiff's motion for partial summary judgment addressed Plaintiff's remaining claim against Defendants for breach of continuing contract under Tenn. Code Ann. § 49-5-409 . . Tenn.Code Ann.”
— Tenn. Code Ann. § 49-5-409(b) — 3 cases
Pamela Dallas v. Shelby Cnty. Bd. of Educ. (Tenn. Ct. App. 2019). “Tenn. Code Ann. § 49-5-409 (2014).12 The trial court denied Ms.”
Candice Mosby v. Fayette Cnty. Bd. of Educ. (Tenn. Ct. App. 2020). “§ 49-1-302 (d)(2)(A) that a teacher’s evaluation “shall be a factor” in all employment-related decisions, may a non-tenured teacher maintain an action challenging her nonrenewal under Tenn. Code Ann. § 49-5-409 when the director of schools makes the decision to non-renew without…”
— Tenn. Code Ann. § 49-5-409(b)(2) — 2 cases
Arnwine v. Union Cnty. Bd. of Educ., 120 S.W.3d 804 (Tenn. 2003). “Tennessee Code Annotated section 49-5-409(b)(2) (1996 & Supp.2000) provides that teachers who are dismissed or not reelected must receive notice prior to April 15 to be applicable to the next succeeding school year.”
Ray v. Bd. of Educ., 72 S.W.3d 657 (Tenn. Ct. App. 2001). “Neither Defendants' nor Plaintiff's motion for partial summary judgment addressed Plaintiff's remaining claim against Defendants for breach of continuing contract under Tenn. Code Ann. § 49-5-409 . . Tenn.Code Ann.”
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