Tennessee Code Annotated

Tenn. Code Ann. § 50-2-107 (2026)

Distribution of service charges or gratuities

✓ current as of May 2026
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Acts 1983, ch. 152, § 1; 1989, ch. 591, § 113; 2012, ch. 895, § 1.


Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 2010–2021 · leading case: Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016).
Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). · cites it 3× “In Hardy , this Court addressed the issue of whether the Tennessee Wage Regulation Act (“TWRA”), specifically Tennessee Code Annotated § 50-2-107 (2014), creates a private right of action against employers who fail to pay employees gratuities they have earned.”
Brown v. Tennessee Title Loans, Inc., 328 S.W.3d 850 (Tenn. 2010). · cites it 2× “15, 1998) (inferring private right of action in tip statute, Tenn.Code Ann. § 50-2-107 (1991), on behalf of plaintiff service employees because statute was intended to protect them and private right would "complement[ ] the [criminal] remedy in the statute by providing a mecha…”
Hamilton Cnty. Emergency Commc'ns Dist. v. BellSouth Telecomm. LLC, 852 F.3d 521 (6th Cir. 2017). “8, 2017), the Tennessee Supreme Court recently held that the "Tip Statute” provision of the Tennessee Wage Regulation Act, T.C.A. § 50-2-107, does not imply a private right of action by a waitress whose employer had collected her tips from her customers but withheld them from…”
Kim Hardy v. Tournament Players Club at Southwind, Inc., d/b/a \TPC Southwind, 513 S.W.3d 427 (2017). · cites it 13× “Whether the majority opinion of the Court of Appeals erred in relying on the standard contained within Owens v.”
Kim Hardy v. Tournament Players Club at Southwind, Inc. d/b/a \TPC Southwind\"" (Tenn. Ct. App. 2015). · cites it 20× “Tenn. Code Ann. § 50-2-107 (2014). Section 107 contains no provision either limiting enforcement to the Department or explicitly creating a private right of action.”
Kim Hardy v. Tournament Players Club at Southwind, Inc. d/b/a \TPC Southwind\" - DISSENT" (Tenn. Ct. App. 2015). · cites it 12× “While I agree with the majority that amendments to Tennessee Code Annotated section 50-2-101 do not govern enforcement of Section 50-2-107, I disagree with the court‟s interpretation of section 107 itself, and I further disagree with this Court‟s holding in Owens.”
Affordable Constr. Servs., Inc. v. Auto-Owners Ins. Co. (Tenn. 2021). · cites it 2× “Following Brown, the Court considered in Hardy whether Tennessee’s Tip Statute, Tennessee Code Annotated section 50-2-107, allowed a server at a private dining club to bring a class action against her employer for violating the Tip Statute.”
Roane Cty. Emer. Commc'ns v. BellSouth (6th Cir. 2017). “8, 2017), the Tennessee Supreme Court recently held that the “Tip Statute” provision of the Tennessee Wage Regulation Act, T.C.A. § 50-2-107, does not imply a private right of action by a waitress whose employer had collected her tips from her customers but withheld them from…”
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