If you only remember one point about filing a lawsuit without a lawyer in Tennessee, remember this: Tennessee calls the opening paper a complaint (or civil warrant in General Sessions). Self-represented parties file in Circuit or Chancery Court (General Sessions Court for many civil claims). Individuals may appear pro se. Entities generally need Tennessee counsel outside limited Sessions exceptions. Procedure, examples, and the opinions below hang off Tennessee Rules of Civil Procedure. E-filing: eFlex / Odyssey (county-dependent). E-filing varies by county. General Sessions Court is the most common paper-friendly forum for self-represented civil claims. Service: Tenn. R. Civ. P. 4; General Sessions statutes. Small claims: General Sessions Court (General Sessions jurisdictional limits apply (commonly $25,000 — confirm local)).
Can you litigate pro se in Tennessee?
Individuals may appear pro se. Entities generally need Tennessee counsel outside limited Sessions exceptions.
Pro se (sometimes in propria persona or self-represented) means you speak for yourself. Courts often construe pro se papers liberally on formatting, but they do not invent claims you failed to plead, excuse missed statutes of limitation, or waive service defects. If a corporation is on the other side with counsel, you will still be held to the Tennessee Rules of Civil Procedure.
Tennessee courts and legal-aid self-help centers publish General Sessions forms.
Tennessee opinions on pro se practice
Darrell Watkins, pro se, State of Tennessee
Darrell Watkins, pro se, State of Tennessee (2004)
…F CRIMINAL APPEALS OF TENNESSEE AT JACKSON DARRELL WATKINS, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Shelby County No. P-27095 Joseph B. Dailey, Judge No. W2003-00995-CCA-R3-HC - Filed January 26, 2004 The Petitioner, Darrell Watkins, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting that th…
Practitioners open Darrell Watkins, pro se, State of Tennessee when Tennessee pro se turns on the distinction in this sentence: "F CRIMINAL APPEALS OF TENNESSEE AT JACKSON DARRELL WATKINS, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Shelby County No. P-27095 Joseph B. Dailey, Judge No." Do not lift it out of the facts the court was deciding.
Larry D. Turnley, Pro Se v. State
Larry D. Turnley, Pro Se v. State (1995)
…RIMINAL APPEALS OF TENNESSEE AT NASHVILLE LARRY D. TURNLEY, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Davidson County No. 95-B-111 J. Randall Wyatt, Judge No. M2003-02153-CCA-R3-HC - Filed November 9, 2004 The Petitioner, Larry D. Turnley, appeals the trial court's dismissal of his petition for the writ of habeas corpus, which was treated as a petition for…
Practitioners open Larry D. Turnley, Pro Se v. State when Tennessee pro se turns on the distinction in this sentence: "RIMINAL APPEALS OF TENNESSEE AT NASHVILLE LARRY D. TURNLEY, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Davidson County No. 95-B-111 J. Randall Wyatt, Judge No. M2003-02153-CCA-R3-HC - Filed November 9, 2004 The Petitioner, Larry D." Do not lift it out of the facts the court was deciding.
LaCorrick C. Williams, Pro Se v. State
LaCorrick C. Williams, Pro Se v. State (1998)
…AL APPEALS OF TENNESSEE AT NASHVILLE LACORRICK C. WILLIAMS, PRO SE v. JAMES M. DAVIS Appeal from the Circuit Court for Wayne County No. 12944 Stella L. Hargrove, Judge No. M2003-00991-CCA-R3-CO Filed March 5, 2004 The Petitioner, LaCorrick C. Williams, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting that this Co…
On pro se, LaCorrick C. Williams, Pro Se v. State speaks to the Tennessee dispute in this passage: "AL APPEALS OF TENNESSEE AT NASHVILLE LACORRICK C. WILLIAMS, PRO SE v. JAMES M. DAVIS Appeal from the Circuit Court for Wayne County No. 12944 Stella L. Hargrove, Judge No. M2003-00991-CCA-R3-CO Filed March 5, 2004 The Petitioner, LaCorrick C." The surrounding opinion shows how the court applied that language to the record.
William Kirk Riley, Pro Se v. State
William Kirk Riley, Pro Se v. State (1998)
…MINAL APPEALS OF TENNESSEE AT NASHVILLE WILLIAM KIRK RILEY, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Davidson County No. 3280 Cheryl A. Blackburn, Judge No. M2002-02302-CCA-OT-CO - Filed October 5, 2004 The Petitioner, William Kirk Riley, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting tha…
William Kirk Riley, Pro Se v. State is worth reading on Tennessee pro se because the court put the point in its own words: "MINAL APPEALS OF TENNESSEE AT NASHVILLE WILLIAM KIRK RILEY, PRO SE v. STATE OF TENNESSEE Appeal from the Criminal Court for Davidson County No. 3280 Cheryl A. Blackburn, Judge No." Use that passage as the starting point, then read the facts that precede it.
Kevin Tate, pro se. v. Bruce Westbrook, Warden
Kevin Tate, pro se. v. Bruce Westbrook, Warden (2004)
…URT OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON KEVIN TATE, PRO SE v. BRUCE WESTBROOK, WARDEN Appeal from the Criminal Court for Shelby County No. P-27279 Joseph B. Dailey, Judge No. W2003-01477-CCA-R3-HC - Filed March 10, 2004 The Petitioner, Kevin Tate, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting that this…
Practitioners open Kevin Tate, pro se. v. Bruce Westbrook, Warden when Tennessee pro se turns on the distinction in this sentence: "URT OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON KEVIN TATE, PRO SE v. BRUCE WESTBROOK, WARDEN Appeal from the Criminal Court for Shelby County No. P-27279 Joseph B. Dailey, Judge No." Do not lift it out of the facts the court was deciding.
Reginald D. Hughes, pro se. v. David Mills, Warden
Reginald D. Hughes, pro se. v. David Mills, Warden (2004)
…RIMINAL APPEALS OF TENNESSEE AT JACKSON REGINALD D. HUGHES, PRO SE v. DAVID MILLS, WARDEN Appeal from the Circuit Court for Lauderdale County No. 5771 Joe H. Walker, III, Judge No. W2003-02486-CCA-R3-HC - Filed March 19, 2004 This matter is before the Court upon the State’s motion to affirm the judgment of the trial court by opinion pursuant to Rule 20, Rules of the Court of Cr…
Practitioners open Reginald D. Hughes, pro se. v. David Mills, Warden when Tennessee pro se turns on the distinction in this sentence: "RIMINAL APPEALS OF TENNESSEE AT JACKSON REGINALD D. HUGHES, PRO SE v. DAVID MILLS, WARDEN Appeal from the Circuit Court for Lauderdale County No. 5771 Joe H. Walker, III, Judge No." Do not lift it out of the facts the court was deciding.
Steven Loach, pro se. v. Kevin Myers, Warden
Steven Loach, pro se. v. Kevin Myers, Warden (2004)
…CRIMINAL APPEALS OF TENNESSEE AT NASHVILLE STEVEN T. LOACH, PRO SE v. KEVIN MYERS, WARDEN Appeal from the Circuit Court for Wayne County No. 236099 Robert Holloway, Judge No. M2003-02085-CCA-R3-HC - Filed March 16, 2004 The Petitioner, Steven T. Loach, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting that this Co…
Tennessee opinions such as Steven Loach, pro se. v. Kevin Myers, Warden are cited where pro se is disputed. The court stated: "CRIMINAL APPEALS OF TENNESSEE AT NASHVILLE STEVEN T. LOACH, PRO SE v. KEVIN MYERS, WARDEN Appeal from the Circuit Court for Wayne County No. 236099 Robert Holloway, Judge No. M2003-02085-CCA-R3-HC - Filed March 16, 2004 The Petitioner, Steven T." That is the language to brief; the rest of the decision supplies the procedural posture.
Corey Johnson, pro se. v. Tony Parker, Warden
Corey Johnson, pro se. v. Tony Parker, Warden (2004)
…OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON COREY JOHNSON, PRO SE v. TONY PARKER, WARDEN Direct Appeal from the Circuit Court for Lake County No. 03-CR-8483 R. Lee Moore, Judge No. W2003-02375-CCA-R3-HC - Filed January 26, 2004 The Petitioner, Corey Johnson, appeals the trial court's denial of his petition for habeas corpus relief. The State has filed a motion requesting that…
Tennessee opinions such as Corey Johnson, pro se. v. Tony Parker, Warden are cited where pro se is disputed. The court stated: "OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON COREY JOHNSON, PRO SE v. TONY PARKER, WARDEN Direct Appeal from the Circuit Court for Lake County No. 03-CR-8483 R. Lee Moore, Judge No." That is the language to brief; the rest of the decision supplies the procedural posture.
Walking through Tennessee facts
Use this walkthrough to see which Tennessee authority does the work at each step.
A person in Tennessee wants to sue without a lawyer and has not yet filed anything.
- Confirm you may appear without counsel: Individuals may appear pro se. Entities generally need Tennessee counsel outside limited Sessions exceptions.
- Draft a complaint (or civil warrant in General Sessions) and file it in Circuit or Chancery Court (General Sessions Court for many civil claims). E-filing: E-filing varies by county. General Sessions Court is the most common paper-friendly forum for self-represented civil claims.
- Serve under Tenn. R. Civ. P. 4; General Sessions statutes. Serve under Rule 4 in Circuit/Chancery — personal service or authorized alternatives. General Sessions often uses a civil warrant served by the sheriff. File returns promptly.
- Expect discovery under Tenn. R. Civ. P. 26–37 govern discovery in Circuit/Chancery. General Sessions discovery is limited. A jury demand follows Demand a jury under Tenn. R. Civ. P. 38 for eligible Circuit claims. General Sessions trials are typically non-jury (appeal can lead to Circuit Court trial de novo).
Missing service or a limitations deadline is not excused because the filer is pro se in Tennessee. The evidence companion is the Tennessee evidence guide.
Role of the judge and the jury
- The judge decides questions of law: what the statute means, whether a pleading states a claim, which evidence is admissible, and how the jury (if any) is instructed. In bench trials and most small-claims matters, the judge also finds the facts.
- The jury decides disputed questions of fact in jury-eligible civil cases when a timely demand is made and any jury fee is paid.
- Demand a jury under Tenn. R. Civ. P. 38 for eligible Circuit claims. General Sessions trials are typically non-jury (appeal can lead to Circuit Court trial de novo).
Practical tip: decide before filing whether you want a jury. Late demands are often waived. Small-claims paths (General Sessions Court) usually trade speed for no jury and limited discovery.
Pleadings: complaint, answer, and motions
Pleadings are the formal papers that frame the lawsuit. In Tennessee the plaintiff's opening paper is typically a complaint (or civil warrant in General Sessions). It should:
- Identify the parties and the court (Circuit or Chancery Court (General Sessions Court for many civil claims) or the small-claims forum).
- Allege facts that, if true, entitle you to relief under a recognized claim.
- Demand judgment (money, injunction, declaratory relief, or other remedies the court can grant).
- Include a jury demand if you want one and the claim is jury-triable.
The defendant responds with an answer (admissions, denials, affirmative defenses) and/or a motion to dismiss challenging legal sufficiency, jurisdiction, or service. Later motions (compel discovery, summary judgment, limine) are usually not “pleadings” in the technical sense, but they drive most civil cases.
Tennessee pleadings opinions
Pam WEBB v. NASHVILLE AREA HABITAT FOR HUMANITY, INC.
Pam WEBB v. NASHVILLE AREA HABITAT FOR HUMANITY, INC., 2011 Tenn. LEXIS 623 (2011)
…aliatory discharge, the trial court granted the defendant’s motion to dismiss for failure to state a claim upon which relief can be granted pursuant to Tennessee Rule of Civil Procedure 12.02(6). The Court of Appeals vacated the trial court’s judgment, holding that the amended complaint sufficiently stated a cause of action for retaliatory discharge. We address the issue of the…
Pam WEBB v. NASHVILLE AREA HABITAT FOR HUMANITY, INC. is worth reading on Tennessee pleadings because the court put the point in its own words: "Tennessee Rule of Civil Procedure 12.02(6). The Court of Appeals vacated the trial court’s judgment, holding that the amended complaint sufficiently stated a cause of action for retaliatory discharge." Use that passage as the starting point, then read the facts that precede it.
Joan STEPHENS, Et Al. v. HOME DEPOT U.S.A., INC., Et Al.
Joan STEPHENS, Et Al. v. HOME DEPOT U.S.A., INC., Et Al., 529 S.W.3d 63 (2016)
…nity, that the trial court applied the wrong standard for a motion to dismiss, and that the particular claims asserted are not barred by the exclusive remedy provision of the workers’ compensation law. We affirm. I. Facts & Procedural History In 2013, Joan Stephens was employed by a temporary staffing company called Belcan Corporation (“Belcan”). 1 She was hired by Belcan to wo…
On pleadings, Joan STEPHENS, Et Al. v. HOME DEPOT U.S.A., INC., Et Al. speaks to the Tennessee dispute in this passage: "We affirm. I. Facts & Procedural History In 2013, Joan Stephens was employed by a temporary staffing company called Belcan Corporation (“Belcan”)." The surrounding opinion shows how the court applied that language to the record.
Charles Crenshaw, pro se. v. State of Tennessee
Charles Crenshaw, pro se. v. State of Tennessee (2004)
…tims in fear of their lives. The State of Tennessee filed a motion to dismiss, citing the Petitioner’s failure to timely file the motion for arrest of judgment. By order entered July 7, 2003, the trial court summarily dismissed the motion, finding that “Petitioner’s request for relief is beyond the time limit required by law.” Petitioner timely appealed the trial court’s denial…
Practitioners open Charles Crenshaw, pro se. v. State of Tennessee when Tennessee pleadings turns on the distinction in this sentence: "The State of Tennessee filed a motion to dismiss, citing the Petitioner’s failure to timely file the motion for arrest of judgment." Do not lift it out of the facts the court was deciding.
Katrina Allen v. Blackbaud, INC.
Katrina Allen v. Blackbaud, INC. (2026)
…eral Sessions Court”). On April 14, 2025, Blackbaud filed a motion to dismiss, noting therein that it was unclear whether Ms. Allen intended to sue Mr. Boor or Blackbaud. On April 17, 2025, Ms. Allen filed a response to the motion, alleging the following breaches: Non-Compliance of written request to redress contract[.] Non[-]performance of Principal Interest being applied…
Katrina Allen v. Blackbaud, INC. is worth reading on Tennessee pleadings because the court put the point in its own words: "Sessions Court”). On April 14, 2025, Blackbaud filed a motion to dismiss, noting therein that it was unclear whether Ms. Allen intended to sue Mr. Boor or Blackbaud. On April 17, 2025, Ms." Use that passage as the starting point, then read the facts that precede it.
In Re Proceeding To Enforce Judgment Against National Partitions, Inc.
In Re Proceeding To Enforce Judgment Against National Partitions, Inc. (2017)
…aph numbering in original omitted.) Plaintiffs then filed a motion to dismiss NP‘s counterclaim on the basis of res judicata. In their motion to dismiss, they asserted the following: The allegations of the [c]ounterclaim concern the same -3- contract and the same set of operative facts as the allegations in the [c]omplaint in the Illinois [a]ction. . . . [I]n a proceeding to re…
On pleadings, In Re Proceeding To Enforce Judgment Against National Partitions, Inc. speaks to the Tennessee dispute in this passage: "Plaintiffs then filed a motion to dismiss NP‘s counterclaim on the basis of res judicata." The surrounding opinion shows how the court applied that language to the record.
Gerald Kiner v. Shelby County Government
Gerald Kiner v. Shelby County Government (2026)
…ated § 10-7- 505(g). On January 2, 2025, the County filed a motion to dismiss, asserting that Mr. Kiner had failed to state a claim upon which relief could be granted pursuant to Tennessee Rule of Civil Procedure 12.02(6). The County reiterated its position that Tennessee Code Annotated § 10-7-504(a)(28) provided an exception and asserted that fairness to vendors dictated that…
Tennessee opinions such as Gerald Kiner v. Shelby County Government are cited where pleadings is disputed. The court stated: "On January 2, 2025, the County filed a motion to dismiss, asserting that Mr. Kiner had failed to state a claim upon which relief could be granted pursuant to Tennessee Rule of Civil Procedure 12.02(6)." That is the language to brief; the rest of the decision supplies the procedural posture.
Loring Justice v. Kim Nelson
Loring Justice v. Kim Nelson (2019)
…al complaint. The court treated defendants’ “response” as a motion to dismiss the amended complaint, which the court then granted. We hold that the court erred when it treated defendants’ “response” as a motion to dismiss the amended complaint. We also hold that the court failed to provide adequate justification for dismissing the amended complaint sua sponte. Accordingly, we v…
Loring Justice v. Kim Nelson is worth reading on Tennessee pleadings because the court put the point in its own words: "The court treated defendants’ “response” as a motion to dismiss the amended complaint, which the court then granted. We hold that the court erred when it treated defendants’ “response” as a motion to dismiss the amended complaint." Use that passage as the starting point, then read the facts that precede it.
TIMGMT Acquisitions, LLC v. 5D Development, Inc.
TIMGMT Acquisitions, LLC v. 5D Development, Inc. (2026)
…ir responsive pleadings, the third-party defendants filed a motion to dismiss under Rule 12 of the Tennessee Rules of Civil Procedure. But the developer argued that the third-party defendants waived their right to file a Rule 12 motion because the agreed order only extended the deadline for “responsive pleadings.” During the hearing on the motion to dismiss, the third-party def…
TIMGMT Acquisitions, LLC v. 5D Development, Inc. is worth reading on Tennessee pleadings because the court put the point in its own words: "Rule 12 of the Tennessee Rules of Civil Procedure. But the developer argued that the third-party defendants waived their right to file a Rule 12 motion because the agreed order only extended the deadline for “responsive pleadings." Use that passage as the starting point, then read the facts that precede it.
How to file and serve in Tennessee
Filing
- Choose the correct forum: Circuit or Chancery Court (General Sessions Court for many civil claims) for larger or complex civil cases; General Sessions Court when your claim fits General Sessions jurisdictional limits apply (commonly $25,000 — confirm local).
- Prepare the complaint (or civil warrant in General Sessions) (and any required cover sheet, civil case information statement, or summons).
- Pay the filing fee or apply for a fee waiver / indigency finding as Tennessee practice allows.
- Obtain a signed summons (or local equivalent) from the clerk after the case is opened.
Governing procedure: Tennessee Rules of Civil Procedure.
Service of process
Filing alone does not start the clock against the defendant in a meaningful way — service does. Authority: Tenn. R. Civ. P. 4; General Sessions statutes.
Serve under Rule 4 in Circuit/Chancery — personal service or authorized alternatives. General Sessions often uses a civil warrant served by the sheriff. File returns promptly.
Defective service is one of the most common reasons pro se cases are dismissed without prejudice (or worse, delayed until limitations problems appear). Keep copies of every affidavit or return.
Tennessee service opinions
Billie Gail HALL, as Surviving Spouse and Administratrix of the Estate of Billy R. Hall, Deceased v. Douglas B
…n were agents properly authorized by appointment to receive service of process on behalf of the corporation and/or one of its physician employees. We hold that none of the individuals who accepted service in this case were agents authorized by appointment to receive service of process on behalf of either the corporation or the individual physician. With specific reference to th…
Billie Gail HALL, as Surviving Spouse and Administratrix of the Estate of Billy R. Hall, Deceased v. Douglas B is worth reading on Tennessee service of process because the court put the point in its own words: "We hold that none of the individuals who accepted service in this case were agents authorized by appointment to receive service of process on behalf of either the corporation or the individual physician." Use that passage as the starting point, then read the facts that precede it.
Cristy Irene FAIR v. Stephen Lynn COCHRAN
Cristy Irene FAIR v. Stephen Lynn COCHRAN, 2013 Tenn. LEXIS 727 (2013)
…ted this appeal to determine whether the return of proof of service of process 412 days after issuance of a summons precludes a plaintiff from relying upon the original commencement of the lawsuit to toll the running of the statute of limitations. We hold that the plain language of Tennessee Rules of Civil Procedure B and 4.03 does not condition the effectiveness of the origina…
Cristy Irene FAIR v. Stephen Lynn COCHRAN is worth reading on Tennessee service of process because the court put the point in its own words: "We hold that the plain language of Tennessee Rules of Civil Procedure B and 4." Use that passage as the starting point, then read the facts that precede it.
Karen STEMPA, Et Al. v. WALGREEN CO., Et Al. — Goddard, J., concurring
…ff not thereafter intentionally prevent or materially delay service of process. Process cannot intentionally be held in abeyance by a plaintiff after an action is commenced. The rules respecting the commencement of an action contemplate the timely issuance of a summons and the placing of summons in the proper channels for service in order to toll the statute of limitations. Int…
On service of process, Karen STEMPA, Et Al. v. WALGREEN CO., Et Al. — Goddard, J., concurring speaks to the Tennessee dispute in this passage: "Process cannot intentionally be held in abeyance by a plaintiff after an action is commenced." The surrounding opinion shows how the court applied that language to the record.
William ALLGOOD and Rose Allgood v. GATEWAY HEALTH SYSTEMS D/B/A Gateway Medical Center and Dr. Christopher Hoffman
…r to the complaint, the physician asserted insufficiency of service of process, and stated that the summons indicated that service was made by the commissioner of insurance through the U.S. mail. No new process was issued. After passage of time, the limitations period for the claim against the physician elapsed. The physician then filed a motion for summary judgment, alleging t…
William ALLGOOD and Rose Allgood v. GATEWAY HEALTH SYSTEMS D/B/A Gateway Medical Center and Dr. Christopher Hoffman is worth reading on Tennessee service of process because the court put the point in its own words: "U.S. mail. No new process was issued. After passage of time, the limitations period for the claim against the physician elapsed." Use that passage as the starting point, then read the facts that precede it.
Stephanie JONES and Howard Jones v. Renga I. VASU, M.D., the Neurology Clinic, and Methodist LeBonheur Hospital
…STEVEN STAFFORD, J., joined. This appeal involves delay of service of process. The plaintiffs filed a complaint against the defendants, alleging medical malpractice by the defendants almost a year earlier. The plaintiffs delayed service on the defendants until they had an expert witness review their claim. Summonses were issued to the defendants over eleven months after the co…
Stephanie JONES and Howard Jones v. Renga I. VASU, M.D., the Neurology Clinic, and Methodist LeBonheur Hospital is worth reading on Tennessee service of process because the court put the point in its own words: "STEVEN STAFFORD, J., joined. This appeal involves delay of service of process. The plaintiffs filed a complaint against the defendants, alleging medical malpractice by the defendants almost a year earlier." Use that passage as the starting point, then read the facts that precede it.
Doris JONES and Billy Jones v. Lisa June COX
Doris JONES and Billy Jones v. Lisa June COX, 2008 Tenn. App. LEXIS 697 (2008)
…ollowing an automobile accident. Appellant failed to effect service of process on the party-defendant to that suit. Appellees retained other counsel and filed a legal malpractice lawsuit against Appellant. Appellees’ new counsel made a strategic decision to withhold service of process on Appellant pending the outcome of the underlying case. Appellant filed a motion to dismiss p…
Doris JONES and Billy Jones v. Lisa June COX is worth reading on Tennessee service of process because the court put the point in its own words: "Appellant failed to effect service of process on the party-defendant to that suit. Appellees retained other counsel and filed a legal malpractice lawsuit against Appellant." Use that passage as the starting point, then read the facts that precede it.
Norma TILLMAN v. Leo P. HAFFEY, Et Al.
Norma TILLMAN v. Leo P. HAFFEY, Et Al., 2001 Tenn. App. LEXIS 350 (2001)
…les of Civil Procedure, a plaintiff may intentionally delay service of process upon a defendant in order to ensure that the defendant’s time to refile a previously non-suited action had expired. This action for malicious prosecution and abuse of process arises out of a civil action in which Appellees, Leo and Robin Haffey, sued Appellant, Norma Tillman, for breach of contract a…
Tennessee opinions such as Norma TILLMAN v. Leo P. HAFFEY, Et Al. are cited where service of process is disputed. The court stated: "Civil Procedure, a plaintiff may intentionally delay service of process upon a defendant in order to ensure that the defendant’s time to refile a previously non-suited action had expired." That is the language to brief; the rest of the decision supplies the procedural posture.
Registering for e-filing
Tennessee's primary electronic filing path is eFlex / Odyssey (county-dependent).
How to register: Register with the e-filing system used by your county, verify identity, and pay fees or seek a pauper’s oath.
Pro se reality check: E-filing varies by county. General Sessions Court is the most common paper-friendly forum for self-represented civil claims.
When you e-file:
- Use PDF/A or the portal's accepted formats; flatten forms before upload.
- Check that party names match the caption exactly.
- Calendar the clerk's acceptance email — a rejected filing is often treated as unfiled.
- Serve other parties under the rules (e-service through the portal may not replace initial service of process).
Discovery
After pleadings, parties exchange information. In Tennessee:
Tenn. R. Civ. P. 26–37 govern discovery in Circuit/Chancery. General Sessions discovery is limited.
Typical tools:
- Interrogatories — written questions answered under oath.
- Requests for production — documents, ESI, and tangible things.
- Requests for admission — force yes/no authenticity or fact stipulations.
- Depositions — live testimony under oath (expensive; plan carefully if you are self-represented).
If the other side stonewalls, a motion to compel and, later, sanctions motions are the enforcement path. Courts expect meet-and-confer first in most jurisdictions.
Tennessee discovery opinions
Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc.
Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc., 2008 Tenn. App. LEXIS 19 (2008)
…ndant. The defendant failed to timely respond to plaintiffs discovery requests, including a request for admission, and failed to comply with the trial court’s order compelling its discovery *164 response. The trial court held that the matters plaintiff sought to have admitted in its discovery request were conclusively admitted pursuant to Tenn. R. Civ. P. 36 and further deemed…
Tennessee opinions such as Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc. are cited where discovery is disputed. The court stated: "The defendant failed to timely respond to plaintiffs discovery requests, including a request for admission, and failed to comply with the trial court’s order compelling its discovery *164 response." That is the language to brief; the rest of the decision supplies the procedural posture.
Stephen Michael West v. Derrick D. Schofield - Concurring in the judgment only
Stephen Michael West v. Derrick D. Schofield - Concurring in the judgment only (2015)
…C.J.S. Constitutional Law § 187, at 274 (2005). During the discovery process, the inmates filed a motion to compel the State to disclose the identities and locations of the physicians, pharmacists, medical examiners, medical personnel, and executioners who are, had been, or might be involved in the creation, production, or administration of the lethal injection protocol. The t…
Tennessee opinions such as Stephen Michael West v. Derrick D. Schofield - Concurring in the judgment only are cited where discovery is disputed. The court stated: "C.J.S. Constitutional Law § 187, at 274 (2005)." That is the language to brief; the rest of the decision supplies the procedural posture.
Kean, Carma v. McRocket, LLC, dba Great Clips
Kean, Carma v. McRocket, LLC, dba Great Clips, 2026 TN WC App. 47 (2026)
…That order was not appealed, and the parties proceeded with discovery. With respect to the current appeal, the employee declined to sign medical records releases, arguing that most of her prior medical records were irrelevant to her claim for benefits. Following a hearing on the employer’s motion to compel, the court ordered her to sign the releases. The employee signed the req…
Practitioners open Kean, Carma v. McRocket, LLC, dba Great Clips when Tennessee discovery turns on the distinction in this sentence: "That order was not appealed, and the parties proceeded with discovery. With respect to the current appeal, the employee declined to sign medical records releases, arguing that most of her prior medical records were irrelevant to her claim for benefits." Do not lift it out of the facts the court was deciding.
Linda Frye v. Ronnie Frye In Re: Judgment of Herbert Moncier
Linda Frye v. Ronnie Frye In Re: Judgment of Herbert Moncier (2001)
…eying post-judgment orders of the Trial Court to respond to discovery and appear for deposition. These orders were entered and the alleged contemptuous conduct occurred before the underlying judgment was reversed by this Court. We affirm. Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Affirmed; Case Remanded. D. MICHAEL SWINEY , J., delivered the opinion…
On discovery, Linda Frye v. Ronnie Frye In Re: Judgment of Herbert Moncier speaks to the Tennessee dispute in this passage: "Trial Court to respond to discovery and appear for deposition. These orders were entered and the alleged contemptuous conduct occurred before the underlying judgment was reversed by this Court. We affirm. Tenn. R. App. P." The surrounding opinion shows how the court applied that language to the record.
The Estate of Carlene C. Elrod v. Michael S. Petty
The Estate of Carlene C. Elrod v. Michael S. Petty (2016)
…al estoppel, the award of expenses and attorney’s fees as a discovery sanction, and the award of discretionary costs. In April 2005, Carlene Elrod, now deceased, signed four quitclaim deeds conveying real property in fee simple to her grandson, Michael Petty. In April 2011, Mrs. Elrod filed a verified complaint to set aside the conveyances on tort grounds including mistake, fra…
The Estate of Carlene C. Elrod v. Michael S. Petty is worth reading on Tennessee discovery because the court put the point in its own words: "In April 2005, Carlene Elrod, now deceased, signed four quitclaim deeds conveying real property in fee simple to her grandson, Michael Petty. In April 2011, Mrs." Use that passage as the starting point, then read the facts that precede it.
Solomon Menche v. White Eagle Property Group, LLC
Solomon Menche v. White Eagle Property Group, LLC (2019)
…es over various business disputes. During the course of the discovery process, the trial court granted three motions to compel against Plaintiff, twice reserving Defendants’ request for attorney’s fees. Eventually, Defendants moved for discovery sanctions against Plaintiff, asking the trial court to award Defendants the attorney’s fees and expenses related to prosecuting the th…
Tennessee opinions such as Solomon Menche v. White Eagle Property Group, LLC are cited where discovery is disputed. The court stated: "During the course of the discovery process, the trial court granted three motions to compel against Plaintiff, twice reserving Defendants’ request for attorney’s fees." That is the language to brief; the rest of the decision supplies the procedural posture.
Southeast Drilling & Blasting Services v. BRS Construction Co.
Southeast Drilling & Blasting Services v. BRS Construction Co. (1997)
…N This extraordinary appeal involves a dispute over whether discovery should be stayed pending resolution of a motion to compel arbitration. Since the application and answers fully set forth the parties’ positions and the material facts, we dispense with further briefing and oral argument and proceed to the merits of the appeal in order to save the parties additional time and e…
Southeast Drilling & Blasting Services v. BRS Construction Co. is worth reading on Tennessee discovery because the court put the point in its own words: "N This extraordinary appeal involves a dispute over whether discovery should be stayed pending resolution of a motion to compel arbitration." Use that passage as the starting point, then read the facts that precede it.
Hurt, Benji v. Vinebrook Homes Trust, Inc.
Hurt, Benji v. Vinebrook Homes Trust, Inc., 2025 TN WC App. 52 (2025)
…e trial court’s decision to deny its third motion to compel discovery. The court granted the employer’s first motion to compel and ordered the employee to provide written authorizations for the release of his medical records. The employee also provided responses to written discovery requests, but the employer asserted they were incomplete and filed another motion to compel, aft…
Practitioners open Hurt, Benji v. Vinebrook Homes Trust, Inc. when Tennessee discovery turns on the distinction in this sentence: "The court granted the employer’s first motion to compel and ordered the employee to provide written authorizations for the release of his medical records." Do not lift it out of the facts the court was deciding.
Rules of evidence (short tour)
Trials and many motion hearings are decided on admissible evidence, not on what you know happened. Tennessee applies the Tennessee Rules of Evidence. Core ideas:
- Relevance — does the proof make a fact of consequence more or less probable?
- Authenticity — is the exhibit what you claim it is?
- Hearsay — is an out-of-court statement offered for its truth, and if so, does an exception apply?
- Privileges — attorney-client, spousal, and other privileges can block inquiry even when the facts are relevant.
For a full Tennessee walkthrough of hearsay, business records, authenticity, and depositions at trial, read the companion guide: Tennessee Evidence Law: Admissibility, Hearsay, and Authenticity.
Summary judgment and other dispositive motions
Many civil cases never reach a jury. A party may move for summary judgment by showing there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law. Pro se litigants lose these motions when they respond with argument instead of affidavits, authenticated exhibits, and pinpoint record citations.
Tennessee summary-judgment opinions
Jan BYRD, Plaintiff-Appellant, v. Dr. Thomas K. HALL, Dr. Maxwell E. Huff, and Dr. David Bruce Coffey
…proper standard to be applied when evaluating a motion for summary judgment under Rule 56 of the Tennessee Rules of Civil Procedure. Jan Byrd, Plaintiff-Appellant, appeals from a judgment of the Circuit Court of Scott County granting summary judgment to Dr. Thomas Hall, Dr. Maxwell Huff, and Dr. David Coffey, Defendants-Appellees. We granted the Plaintiffs Rule 11 application…
Jan BYRD, Plaintiff-Appellant, v. Dr. Thomas K. HALL, Dr. Maxwell E. Huff, and Dr. David Bruce Coffey is worth reading on Tennessee summary judgment because the court put the point in its own words: "Rule 56 of the Tennessee Rules of Civil Procedure. Jan Byrd, Plaintiff-Appellant, appeals from a judgment of the Circuit Court of Scott County granting summary judgment to Dr. Thomas Hall, Dr. Maxwell Huff, and Dr. David Coffey, Defendants-Appellees." Use that passage as the starting point, then read the facts that precede it.
Michelle Rye v. Women Center of Memphis, MPLLC - Concurring in Part, Dissenting in Part
…ppeal in this healthcare liability action to reconsider the summary judgment standard adopted in Hannan v. Alltel Publishing Co., 270 S.W.3d 1 (Tenn. 2008). The Court of Appeals' concluded that the Hannan standard requires reversal of the trial court’s decision granting summary'judgment to the defendants on certain of the plaintiffs’ claims. We hereby overrule Hannan and return…
On summary judgment, Michelle Rye v. Women Center of Memphis, MPLLC - Concurring in Part, Dissenting in Part speaks to the Tennessee dispute in this passage: "Hannan v. Alltel Publishing Co., 270 S.W.3d 1 (Tenn. 2008). The Court of Appeals' concluded that the Hannan standard requires reversal of the trial court’s decision granting summary'judgment to the defendants on certain of the plaintiffs’ claims." The surrounding opinion shows how the court applied that language to the record.
Tennie MARTIN Et Al. v. NORFOLK SOUTHERN RAILWAY COMPANY Et Al.
Tennie MARTIN Et Al. v. NORFOLK SOUTHERN RAILWAY COMPANY Et Al., 2008 Tenn. LEXIS 863 (2008)
…comes before .us on an appeal of the trial court’s grant of summary judgment in favor of the defendants. Because the plaintiffs have established the existence of several genuine issues of material fact, we conclude that summary judgment is inappropriate. We further conclude that the trial court did not err in excluding evidence of a defendant’s subsequent remedial measures. We…
Practitioners open Tennie MARTIN Et Al. v. NORFOLK SOUTHERN RAILWAY COMPANY Et Al. when Tennessee summary judgment turns on the distinction in this sentence: "Because the plaintiffs have established the existence of several genuine issues of material fact, we conclude that summary judgment is inappropriate. We further conclude that the trial court did not err in excluding evidence of a defendant’s subsequent remedial measures." Do not lift it out of the facts the court was deciding.
Marvin McCARLEY and Ellyse McCarley, Plaintiffs/Appellants, v. WEST QUALITY FOOD SERVICE D/B/A Kentucky Fried
…Chicken. The trial court granted the defendant’s motion for summary judgment. The Court of Appeals affirmed and held that the plaintiffs’ proof was insufficient to establish the element of causation. We granted appeal to address: (1) the Court of Appeals’ analysis in summary judgment dispositions; and (2) the quantum and type of proof plaintiffs must proffer to survive summary…
On summary judgment, Marvin McCARLEY and Ellyse McCarley, Plaintiffs/Appellants, v. WEST QUALITY FOOD SERVICE D/B/A Kentucky Fried speaks to the Tennessee dispute in this passage: "Chicken. The trial court granted the defendant’s motion for summary judgment. The Court of Appeals affirmed and held that the plaintiffs’ proof was insufficient to establish the element of causation." The surrounding opinion shows how the court applied that language to the record.
William Gayle WARREN, Plaintiff-Appellant, v. the ESTATE OF Jerry N. KIRK, Deceased and Belton Duncan D/B/A Delta
…f the Court of Appeals affirming the trial court’s grant of summary judgment for the owner of a vehicle in an action for personal injuries caused by the negligent operation of the vehicle. The Court of Appeals found that there is no genuine issue of material fact as to the existence of a master-servant relationship between the driver and the owner and dismissed the complaint ag…
William Gayle WARREN, Plaintiff-Appellant, v. the ESTATE OF Jerry N. KIRK, Deceased and Belton Duncan D/B/A Delta is worth reading on Tennessee summary judgment because the court put the point in its own words: "Court of Appeals affirming the trial court’s grant of summary judgment for the owner of a vehicle in an action for personal injuries caused by the negligent operation of the vehicle." Use that passage as the starting point, then read the facts that precede it.
Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc.
Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc., 2008 Tenn. App. LEXIS 19 (2008)
…Rule 37 and consequently affirm the trial court’s grant of summary judgment in plaintiffs favor. I. Background Meyer Laminates (SE), Inc. (“Meyer”) filed its complaint in this action against Primavera Distributing, Inc. (“Primav-era”), on March 9, 2004, alleging that Pri-mavera owed Meyer $373,777.44 for flooring materials purchased by Primavera from Meyer. On or about March 1…
Meyer Laminates (Se), Inc. v. Primavera Distributing, Inc. is worth reading on Tennessee summary judgment because the court put the point in its own words: "Rule 37 and consequently affirm the trial court’s grant of summary judgment in plaintiffs favor. I. Background Meyer Laminates (SE), Inc. (“Meyer”) filed its complaint in this action against Primavera Distributing, Inc." Use that passage as the starting point, then read the facts that precede it.
Of Law. Byrd v. Hall, 847 S.W.2D 208, 214 (Tenn. 1993). The Party Seeking Summary Judgment Has
…une 29, 2000 The Trial Court granted proponents of the Will Summary Judgment on the ground there was no evidence of undue influence. Contestant appealed. Tenn. R. App. P.3 Appeal as of Right; Judgment of the Circuit Court Affirmed. FRANKS, J., delivered the opinion of the court, in which GODDARD , P.J., and SUSANO, J., joined. John K. Harber, Pryor, Flynn, Priest and Harber, Kn…
On summary judgment, Of Law. Byrd v. Hall, 847 S.W.2D 208, 214 (Tenn. 1993). The Party Seeking Summary Judgment Has speaks to the Tennessee dispute in this passage: "The Trial Court granted proponents of the Will Summary Judgment on the ground there was no evidence of undue influence. Contestant appealed. Tenn. R. App. P.3 Appeal as of Right; Judgment of the Circuit Court Affirmed. FRANKS, J." The surrounding opinion shows how the court applied that language to the record.
In Re Proceeding To Enforce Judgment Against National Partitions, Inc.
In Re Proceeding To Enforce Judgment Against National Partitions, Inc. (2017)
…d a motion for default judgment. NP also filed a motion for summary judgment asking the court to deny entry of the Illinois judgment. It stated the following in its motion for summary judgment: [NP] did not appear in the . . . case . . . and, therefore, has not submitted to the jurisdiction of the Circuit Court for Cook County, Illinois. Neither jurisdiction nor venue was appro…
Tennessee opinions such as In Re Proceeding To Enforce Judgment Against National Partitions, Inc. are cited where summary judgment is disputed. The court stated: "NP also filed a motion for summary judgment asking the court to deny entry of the Illinois judgment. It stated the following in its motion for summary judgment: [NP] did not appear in the . . . case . . ." That is the language to brief; the rest of the decision supplies the procedural posture.
How LawDiver can help
LawDiver is built for researching the same authorities a courtroom expects — not for inventing cites.
- LawDiver search — From this guide page, the search rail is scoped to Tennessee. Search phrases like
pro se,service of process,motion to compel, or your statute number. - Corpus-linked opinions — Every case block above links to a
/casedisplayopinion id that exists in LawDiver's caselaw corpus. Do not paste outside citations into filings unless you have verified them. - Statutes — Where Tennessee codes are mirrored, open the linked statute sections from this article and read the live text before quoting.
- GoodLaw / citator workflow — Before you rely on an older opinion, check how later Tennessee cases treat it.
- Evidence companion — Use the Tennessee evidence guide when you are preparing exhibits or opposing a motion in limine.
- AI research with grounding — Prefer tools that require retrieval from your matter and the LawDiver corpus over chatbots that invent case names.
LawDiver does not file documents for you, give legal advice, or replace a lawyer when the stakes, opposing counsel, or entity-representation rules require one.
Tennessee case law highlights
Use the topic sections above for pro se practice, pleadings, service, discovery, and summary judgment. Re-run LawDiver searches before hearings — new published opinions appear continuously.
Checklist before you file in Tennessee
- Confirm you (not an entity) may appear pro se for this claim.
- Pick General Sessions Court vs Circuit or Chancery Court (General Sessions Court for many civil claims) based on amount and remedy.
- Draft a complaint (or civil warrant in General Sessions) that states facts and a legal theory.
- Register on eFlex / Odyssey (county-dependent) (or confirm paper filing is allowed).
- Arrange proper service under Tenn. R. Civ. P. 4; General Sessions statutes.
- Calendar answer deadlines, discovery cutoffs, and any jury-demand deadline.
- Research controlling Tennessee cases and the Tennessee Rules of Evidence on LawDiver.
- Consider limited-scope or full representation if the other side has counsel or the claim exceeds small-claims complexity.
Key takeaways
- Individuals may appear pro se. Entities generally need Tennessee counsel outside limited Sessions exceptions.
- Main trial forum: Circuit or Chancery Court (General Sessions Court for many civil claims). Smaller disputes often belong in General Sessions Court (General Sessions jurisdictional limits apply (commonly $25,000 — confirm local)).
- Procedure: Tennessee Rules of Civil Procedure. Opening paper: a complaint (or civil warrant in General Sessions).
- Service: Tenn. R. Civ. P. 4; General Sessions statutes. Serve under Rule 4 in Circuit/Chancery — personal service or authorized alternatives.
- E-filing: eFlex / Odyssey (county-dependent). E-filing varies by county.
- Pair this page with the LawDiver search rail (scoped to Tennessee) and the Tennessee evidence guide.
Primary search phrases this page targets: file a lawsuit without a lawyer Tennessee; Tennessee pro se; Tennessee eFiling; how to sue in Tennessee.
Contents
- What is a statute, case, rule, and regulation?
- Can you litigate pro se in Tennessee?
- Role of the judge and the jury
- Pleadings: complaint, answer, and motions
- How to file and serve in Tennessee
- Registering for e-filing
- Discovery
- Rules of evidence (short tour)
- Summary judgment and other dispositive motions
- How LawDiver can help
- Tennessee case law highlights
- Frequently asked questions
What is a statute, case, rule, and regulation?
Self-represented litigants lose cases when they confuse sources of law. Use these definitions when you research on LawDiver:
| Source | What it is | How you use it in Tennessee |
|---|---|---|
| Statute | A law enacted by the legislature (or Congress) | Creates rights, duties, damages caps, notice periods, and causes of action |
| Case (opinion) | A written decision of a court resolving a dispute | Interprets statutes and rules; binds lower courts in the same hierarchy when it is controlling precedent |
| Court rule | A procedural regulation adopted by the judiciary | Tells you how to plead, serve, discover, and try a case — e.g. Tennessee Rules of Civil Procedure |
| Regulation | A rule issued by an executive agency under statutory authority | Matters when your claim involves licensed industries, benefits, or administrative prerequisites |
| Local rule / administrative order | County- or court-specific filing practice | Often controls e-filing mandates, cover sheets, and hearing calendars |
A winning Tennessee theory usually needs all three of: (1) a substantive statute or common-law claim, (2) a pleading that satisfies the civil rules, and (3) admissible evidence under the Tennessee Rules of Evidence.
Frequently asked questions
How do I file a lawsuit without a lawyer in Tennessee?
Prepare a complaint (or civil warrant in General Sessions), file it in the correct Tennessee court (Circuit or Chancery Court (General Sessions Court for many civil claims) or General Sessions Court), pay or waive the fee, obtain a summons, and complete service under Tenn. R. Civ. P. 4; General Sessions statutes. Register for eFlex / Odyssey (county-dependent) when e-filing is required or available.
What is the difference between a statute and a court rule?
A statute creates substantive rights and duties. A court rule (such as Tennessee Rules of Civil Procedure) controls procedure — captions, service, discovery, and trial mechanics. You usually need both.
Do I need to register for e-filing?
E-filing varies by county. General Sessions Court is the most common paper-friendly forum for self-represented civil claims. Registration steps: Register with the e-filing system used by your county, verify identity, and pay fees or seek a pauper’s oath.
Will I get a jury?
Demand a jury under Tenn. R. Civ. P. 38 for eligible Circuit claims. General Sessions trials are typically non-jury (appeal can lead to Circuit Court trial de novo).
What happens in discovery?
Tenn. R. Civ. P. 26–37 govern discovery in Circuit/Chancery. General Sessions discovery is limited.
How does LawDiver help a pro se litigant?
It lets you search and read Tennessee opinions and statutes that actually exist in the LawDiver corpus, with links you can verify — reducing the risk of hallucinated citations — while you still remain responsible for filing, service, and courtroom advocacy.
Disclaimer
LawDiver publishes this guide for public legal-information and SEO education purposes. It is not a substitute for advice from a licensed Tennessee attorney. Court rules, e-filing vendors, fee schedules, and jurisdictional limits change. Verify every citation and deadline against official Tennessee sources and the live LawDiver corpus before relying on them in a filing.