City of Harriman, Tennessee v. Roane County Election Commission, 354 S.W.3d 685

Tennessee Chapter 58 governs county growth plans, urban growth boundaries, and annexation procedures for municipalities.
Roane County adopted a countywide growth plan via its coordinating committee (2005–2010).
Harriman sought to amend its urban growth boundary to include Midtown for annexation; Kingston planned to annex the same Midtown by referendum.
Harriman filed suit to halt Kingston’s annexation referendum and to challenge the voidness of Harriman’s ordinance.
Chancery court dismissed Harriman’s ordinance as void; Court of Appeals reversed; Supreme Court granted permission to review.
Supreme Court held that 6-58-111(d)(1) requires amendment of the growth plan before any ordinance annexation beyond a boundary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a municipality annex territory beyond its urban growth boundary by ordinance without amending the plan?	Harriman argued the statute provides a general rule with an exception.	Kingston argued annexation by ordinance is permissible with proper amendment procedures.	No; amendment required before ordinance annexation beyond boundary.
What steps must be followed to amend the growth plan to permit such annexation?	Harriman contends proposed amendment suffices for exception.	Kingston contends full amendment process under 6-58-104 applies.	Amendment must go through full 6-58-104 procedures and be ratified by all parties.
Does referendum provide an alternative path when amendment is not completed?	N/A (focus on ordinance path).	Referendum is the alternative when amendment is not completed.	Referendum remains the alternative, but Harriman did not complete amendment.
Do Harriman’s and Kingston’s actions create conflicts under Chapter 58?	Harriman’s ordinance conflicts with Kingston’s referendum.	No conflict if proper procedures followed.	No conflict; Harriman’s ordinance void; Kingston’s referendum stands.

State ex rel. Tipton v. City of Knoxville, 205 S.W.3d 456 (Tenn. Ct. App. 2006) (addressed urban growth boundary considerations)
City of Alcoa v. Tenn. Local Gov’t Planning Advisory Comm., 123 S.W.3d 351 (Tenn. Ct. App. 2003) (discussed growth plan adoption and dispute resolution)
Larsen-Ball v. Ball, 301 S.W.3d 228 (Tenn. 2010) (statutory construction reviewed de novo)
In re C.K.G., 173 S.W.3d 714 (Tenn. 2005) (interpretation of statutory language in context)
Marsh v. Henderson, 424 S.W.2d 193 (Tenn. 1968) (plain meaning governs statutory interpretation)
Graham v. Caples, 325 S.W.3d 578 (Tenn. 2010) (harmonious operation of laws; avoid conflict between statutes)
Wilson v. Johnson Cnty., 879 S.W.2d 807 (Tenn. 1994) (statutes relating to same subject construed together)