TEMPLATE – STATE COURT COMPLAINT (BREACH OF CONTRACT)
Jurisdiction: Tennessee

[// GUIDANCE: This template is drafted to comply with the Tennessee Rules of Civil Procedure (“Tenn. R. Civ. P.”) and common state-court practice. Customize all bracketed language, delete guidance boxes before filing, and verify local rules for the specific judicial district.]

TABLE OF CONTENTS

1. Caption & Style of Case
2. Introductory Statement
3. Parties
4. Jurisdiction & Venue
5. Facts Common to All Claims
6. Cause of Action – Breach of Contract
7. Damages
8. Conditions Precedent & Performance/Excuse
9. Prayer for Relief
10. Demand for Jury Trial (Optional)
11. Reservation of Rights
12. Certification Pursuant to Tenn. R. Civ. P. 11
13. Verification (If Required)
14. Signature Block
15. Certificate of Service

1. CAPTION & STYLE OF CASE

IN THE [CIRCUIT/CHANCERY/GENERAL SESSIONS] COURT FOR [COUNTY] COUNTY, TENNESSEE

[PLAINTIFF NAME], )
)
Plaintiff, )
)
v. ) No. ____
)
[DEFENDANT NAME], )
)
Defendant. )

COMPLAINT FOR BREACH OF CONTRACT

2. INTRODUCTORY STATEMENT

1. Plaintiff [FULL LEGAL NAME] (“Plaintiff”) brings this action against Defendant [FULL LEGAL NAME] (“Defendant”) for breach of contract arising out of Defendant’s failure to perform under the [TITLE OF CONTRACT] dated [DATE] (the “Agreement”).
2. Plaintiff seeks compensatory damages, pre- and post-judgment interest, attorneys’ fees where allowable, costs of suit, and all other relief the Court deems just and proper.

3. PARTIES

3. Plaintiff is a [STATE] [corporation/limited liability company/individual] with its principal place of business at [ADDRESS].
4. Defendant is a [STATE] [corporation/LLC/individual] whose principal place of business is [ADDRESS] and who may be served with process through its registered agent:
   [NAME OF AGENT]
   [STREET ADDRESS]
   [CITY, STATE ZIP].

[// GUIDANCE: Verify the registered agent via the Tennessee Secretary of State. For service on individuals, list a physical residence address per Tenn. R. Civ. P. 4.04.]

4. JURISDICTION & VENUE

5. This Court has subject-matter jurisdiction pursuant to Tenn. Code Ann. § 16-10-101 and Tenn. Const. art. VI, § 10, because the amount in controversy exceeds $[AMOUNT] and the claims arise under Tennessee contract law.
6. Venue is proper in this County under Tenn. Code Ann. § 20-4-101 because [venue basis—e.g., Defendant resides in this County and/or the cause of action arose here].
7. Defendant is subject to personal jurisdiction in Tennessee because it [is domiciled here / transacts business here / committed the acts complained of in this State].

5. FACTS COMMON TO ALL CLAIMS

8. On [DATE], the parties executed the Agreement, attached as Exhibit A.
9. Under the Agreement, Defendant agreed to:
   a. [Describe primary obligation];
   b. [Describe additional obligations].
10. Plaintiff fully performed or stood ready to perform all material obligations, including [specify].
11. Beginning on or about [DATE], Defendant materially breached the Agreement by:
    a. Failing to [describe breach];
    b. [Additional breaches].
12. Plaintiff provided Defendant with written notice of breach on [DATE] pursuant to Section [__] of the Agreement.
13. Despite notice and a [__]-day cure period, Defendant has failed to cure.

6. CAUSE OF ACTION – BREACH OF CONTRACT

14. Plaintiff realleges and incorporates paragraphs 1–13.
15. The Agreement is a valid, binding contract supported by adequate consideration.
16. Defendant’s conduct constitutes a material breach of the Agreement.
17. As a direct and proximate result of Defendant’s breach, Plaintiff has suffered damages in excess of $[AMOUNT], including but not limited to [lost profits/out-of-pocket costs/etc.].

7. DAMAGES

18. Plaintiff seeks:
    a. Compensatory damages in an amount to be proven at trial, but not less than $[AMOUNT];
    b. Pre-judgment interest pursuant to Tenn. Code Ann. § 47-14-123;
    c. Post-judgment interest at the statutory rate;
    d. Attorneys’ fees and costs where permitted by Section [__] of the Agreement and Tenn. R. Civ. P. 54.04(2);
    e. Such other relief as the Court deems equitable and just.

8. CONDITIONS PRECEDENT & PERFORMANCE/EXCUSE

19. All conditions precedent to Defendant’s performance have been satisfied, waived, or are otherwise excused.

9. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant, awarding the damages and relief enumerated above, together with all further relief to which Plaintiff is entitled.

10. DEMAND FOR JURY TRIAL (Optional)

20. Pursuant to Tenn. R. Civ. P. 38.01, Plaintiff demands a trial by jury on all issues so triable.

11. RESERVATION OF RIGHTS

21. Plaintiff reserves the right to amend this Complaint to assert additional claims and increase the ad damnum as discovery may warrant under Tenn. R. Civ. P. 15.

12. CERTIFICATION PURSUANT TO TENN. R. CIV. P. 11

I certify that to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, this filing is not presented for any improper purpose; the claims are warranted by existing law or a non-frivolous argument for its modification; and the factual contentions have evidentiary support.

13. VERIFICATION (Include if verified complaint is required or advisable)

STATE OF _ )
) VERIFICATION
COUNTY OF ______ )

I, [NAME], being duly sworn, depose and state that I am the [TITLE] of Plaintiff [ENTITY], that I have read the foregoing Complaint, and that the factual statements therein are true and correct to the best of my knowledge, information, and belief.

[NAME]
Subscribed and sworn before me on this ___ day of ____, 20__.

Notary Public
My Commission Expires: ____

14. SIGNATURE BLOCK

Respectfully submitted,

[ATTORNEY NAME] (TN BPR No. __)
[Firm Name]
[Street Address]
[City, State ZIP]
Phone: () -
Email: [email address]
Attorney for Plaintiff

15. CERTIFICATE OF SERVICE

I certify that on this ___ day of ____, 20__, a copy of the foregoing was served via [method permitted under Tenn. R. Civ. P. 5.02] upon:

[Opposing Counsel Name]
[Firm Name]
[Address]
Email: [email]

[Attorney Name]

APPENDIX A – PRACTICE NOTES & STATE-SPECIFIC GUIDANCE

[// GUIDANCE: Delete before filing.]

A. Pleading Requirements
• Tenn. R. Civ. P. 8.01 requires “a short and plain statement” of the claim and a demand for relief.
• Attach the operative contract as an exhibit (Rule 10.03).

B. Service of Process
• Commence the action by filing the Complaint and obtaining a civil summons under Rule 3.
• Complete and have the clerk issue summons (Form 1). Service methods are set out in Rule 4.04.
• Ensure the summons is returned within 90 days (Rule 4.03).

C. Discovery Limits
• Interrogatories: 30 including sub-parts (Rule 33.01(1)).
• Depositions: One-day/7-hour limit per deponent unless otherwise stipulated (Rule 30.02(4)).
• Requests for Admission: No numeric limit, but must be proportional per Rule 26.02.

D. Injunctive Relief
• If seeking temporary or permanent injunction, add a separate count referencing Tenn. R. Civ. P. 65 and include a verified statement of irreparable harm.

E. General Sessions Practice
• For claims ≤ $25,000, General Sessions Court is often faster and less formal. Modify caption, omit jury demand, and verify local limit.

F. Jury Demand Timing
• Must be made in the pleadings or within 15 days after service of the last pleading directed to such issue (Rule 38.02).

G. Electronic Filing
• Many counties require e-filing. Confirm formatting (PDF/Word) and signature requirements (scanned or s/Name).

END OF TEMPLATE