Stephen H. Cook v. David L. Alley, Sr., 419 S.W.3d 256

Judgment entered June 11, 1990 in favor of plaintiff against Alley and Alley, Sr. for nominal damages; award later modified to $180,000 by Court of Appeals and not credited for reasonable commission by the Tennessee Supreme Court.
Tennessee Supreme Court affirmed the $180,000 but reversed the commission credit, remanding for consistent proceedings.
Trial Court entered a nunc pro tunc judgment on March 7, 1996 to December 10, 1992, and awarded post-judgment interest from that nunc pro tunc date.
Plaintiff and successors filed a motion to revive the judgment on May 30, 2000; revival order entered June 14, 2000.
Plaintiff died in 2002; successors later sought enforcement via Rule 69.07 and asserted the lien remained effective until June 14, 2010.
In November 2010, successors moved to extend the judgment for an additional ten years (to December 10, 2022); trial court extended to March 7, 2026, based on a ruling that the extension period begins from the original ten-year anniversary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the first ten-year extension runs from the original judgment date or from the extension order date.	Successors argue extensions begin ten years from the order granting extension.	Defendants contend extensions begin ten years from the original entry date of the judgment.	Extension runs from the original ten-year anniversary, not from the extension order date.
Whether the original final judgment was effective from December 10, 1992 or March 7, 1996.	Original nunc pro tunc date controls; there was post-judgment interest from 1992.	Original final judgment effective date should be March 7, 1996.	Original judgment was effective from December 10, 1992; extended to 2022 after two renewals.

Whitworth v. Thompson, 76 Tenn. 480 (Tenn. 1881) (extension and revival principles for judgments)
Kruetzmann v. Bauman, 609 S.W.2d 736 (Tenn. Ct. App. 1980) (extensions are not new judgments; life extends ten years beyond prior term)
Cantrell v. Humana of Tennessee, Inc., 617 S.W.2d 901 (Tenn. Ct. App. 1981) (nunc pro tunc entries require clear evidence of previous, announced judgment)
Rush v. Rush, 97 Tenn. 279, 37 S.W. 13 (Tenn. 1896) (nunc pro tunc and judgment entry standards)
Blackburn v. Blackburn, 270 S.W.3d 42 (Tenn. 2008) (standard for granting nunc pro tunc relief; record alignment)
Jackson v. Jarratt, 52 S.W.2d 137 (Tenn. 1932) (abuse of discretion standard for nunc pro tunc entries)
Zeitlin v. Zeitlin, 544 S.W.2d 103 (Tenn. Ct. App. 1976) (existence of intent to enter judgment before recording)