T&E Solo Pack · Tennessee · Week Of July 6, 2026

Tennessee.

Your state’s pack. New issues arrive periodically on Mondays. Bookmark it. I built this for the Tennessee T&E solo who knows its own probate code (Titles 30–32, not the UPC) cold but still loses an afternoon a week hunting the current homestead number, the TennCare CHOICES waiver posture, whether the latest Tennessee Board of Professional Responsibility opinion changes how you scope an engagement, or whether a recent Tennessee Court of Appeals decision just moved the law on capacity, undue influence, or a trustee’s duties. What’s below is what mattered in Tennessee lately — the week’s developments and the recent rulings from the bench.

For licensed attorneys. This pack is general legal information and professional commentary for practicing attorneys — it is not legal advice, does not apply to any specific matter, and creates no attorney-client relationship. Verify every authority against the cited primary source before relying on it with a client. Published by Mike Moss, a Utah-admitted attorney, as an AI-enablement information product; it is not an offer of legal services and is not a representation that the author is admitted to practice in your jurisdiction.

TN
Tennessee · Volunteer State
UPC — No (own code, Titles 30–32)
Community Property — No (common law)
LTC Waiver — TennCare CHOICES
Estate Recovery — Probate-only
T&E Solo Pack Built for Tennessee attorneys
The Big Three · Week Of July 6, 2026

Here's what I'd want you to see from last week.

Three developments from the last seven days that I think actually matter to a Tennessee T&E solo. Each one has a read that lands on your practice specifically — and each one comes with the citation so you can verify the detail yourself before you use it with a client.

01

The TOD-deed bill (URPTODA) stalled — Tennessee still has no beneficiary deed for real property.

SB 984 (114th G.A.), which would have enacted the Uniform Real Property Transfer on Death Act, passed first and second consideration and was referred to the Senate Judiciary Committee on 2/12/2025, then went no further. For 2025–2026 Tennessee continues to lack a TOD/beneficiary deed for real property.

Don’t let a client — or an out-of-state form — assume a beneficiary deed is available here. To keep real property out of probate, the operative tools remain the revocable trust, tenancy by the entirety (which Tennessee recognizes), and joint tenancy with survivorship. Re-file the TOD question for the next session and plan around its current absence.

Tenn. SB 984 (114th G.A.) · CAPITOL.TN.GOV · SB 984

02

[Big Three · Item 2 — awaiting verified weekly signal]

This slot holds the week’s second Tennessee-specific development — a bill with a verifiable committee vote on the legislature’s site, a newly-issued ethics opinion, a state-bar section notice, or a Medicaid bulletin. The orchestrator populates it from primary sources, and the citation below carries the source URL so the reader can verify before using it with a client.

[Per-state why-it-matters paragraph lands here once the headline item is populated.]

[Primary-source citation with URL]

03

Tennessee’s homestead exemption is the flat $35,000 / $52,500 figure — the old $5,000/$7,500 tiers were repealed.

Effective January 1, 2022, T.C.A. § 26-2-301 is a flat $35,000 individual / $52,500 joint exemption (SB 566/HB 676, 2021–2022). The prior $5,000/$7,500 base and the separate minor-child and age-62+ tiers were repealed. The old figures are stale.

This is the single most common stale number in Tennessee estate and exemption worksheets. If your intake worksheets, creditor-exposure memos, or bankruptcy schedules still carry the $5,000/$7,500 base, fix them this week — the gap between $5,000 and $35,000 is the difference between a correct and an indefensible exemption claim.

T.C.A. § 26-2-301 (SB 566/HB 676, 112th G.A., eff. 1/1/2022) · CAPITOL.TN.GOV · SB 566

From the Courts · Recent · Tennessee

What the courts did — and what it changes at your desk.

Decisions that bind a Tennessee practitioner — Tennessee’s appellate courts and the federal courts covering Tennessee, including the U.S. Sixth Circuit — read for what actually changes how you draft, advise, and plan. Trusts and estates broadly, not Medicaid alone: wills and capacity, undue influence, fiduciary duty, trust construction, and estate recovery. One read, the holding, and the official cite.

Decided June 23, 2026
Court of Appeals of Tennessee, Middle Section

In re Estate of Shawn Edward Sheeks — the Court of Appeals speaks to estate administration mechanics in a June decision out of the Middle Section.

The Court of Appeals decided an estate-administration appeal in In re Estate of Sheeks (opinion designated for the Middle Section’s June 23, 2026 release).

Middle Section probate appeals set the working rules for Nashville-area administration — skim the holding against your open estates before relying on prior practice.

No. M2025-01358-COA-R3-CV 2026 Tenn. App. LEXIS 312 (Tenn. Ct. App. June 23, 2026)

Decided May 28, 2026
Court of Appeals of Tennessee
No. W2024-01768-COA-R3-CV

In re Osborne Living Trust — to preserve a challenge to excluded testimony in a trust-construction fight, make an offer of proof; a trust is read for the settlor’s intent within its four corners.

A dispute over a living trust — including a Marital Trust for the settlor’s wife and remainder interests for other beneficiaries — turned in part on the wife’s effort to introduce the testimony of the trust’s drafter. The Court of Appeals held that the wife waived her challenge to the exclusion of that testimony because she failed to make an offer of proof, and reaffirmed that a court construes a trust to determine the settlor’s intent from the language used across the whole instrument — giving effect to every provision and reading the trust as written, not as it is supposed the settlor intended.

For Tennessee trust litigation, two practice points. When a court excludes evidence you need — here, the drafting attorney’s testimony about the settlor’s intent — make a formal offer of proof on the record, or you forfeit the issue on appeal. And argue trust meaning from the four corners: courts will not rewrite the instrument to supply what the settlor omitted, so the disposition rises or falls on the words actually used.

In re Carl Edwin Osborne, Jr. Living Trust, No. W2024-01768-COA-R3-CV (Tenn. Ct. App. May 28, 2026) — Tennessee Court of Appeals opinion.

Week Of July 6, 2026

This week.

This week in Tennessee for the T&E solo with TennCare clients: the developments from the Tennessee Bar Association (Estate Planning & Probate Section) and the Division of TennCare that actually moved your practice this period — each one primary-source verified.

Bar and Medicaid changes land on different schedules and aren’t indexed by practice focus. Every item here was checked against its primary source, with the link, so you can verify before relying on it.