Sandy Eugene Womack v. Correction Corporation Of America D/B/A Whiteville Correctional Facility, 448 S.W.3d 362

Womack, an inmate, alleged medical neglect at a private CCA facility (Whiteville) under contract with the state.
Plaintiff’s suit was filed in Davidson County; defendant moved to transfer to Hardeman County under §41-21-803.
Trial court transferred to Hardeman County, then granted interlocutory appeal to determine venue law.
Court of Appeals held that §41-21-803 effectively localizes prisoner actions, thus Hardeman County was proper.
Tennessee Supreme Court held §41-21-803 does not apply to actions accruing in privately operated facilities and reversed/remanded for further proceedings.
Court taxed costs to CCA and its surety, remanding for consistent handling of venue].
Note: The Court expressly overruled Hayes v. State to the extent inconsistent with its holding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §41-21-803 localizes venue for actions accruing in privately operated facilities	Womack argues the statute does not apply to private facilities.	CCA contends the statute localizes all prisoner actions, including private facilities.	§41-21-803 does not apply to privately operated facilities; venue not localized by statute.

Hawkins v. Tennessee Dep’t of Corr., 127 S.W.3d 749 (Tenn. Ct. App. 2002) (statute localizes transitory prisoner actions)
Davis v. Holland, 31 S.W.3d 574 (Tenn. Ct. App. 2000) (early recognition of §41-21-803 effects on venue)
Hayes v. State, 341 S.W.3d 293 (Tenn. Ct. App. 2009) (venue issues in prisoner actions; subsequent interpretation questioned)