There are at least two types of cases that cannot be recommenced after they have been voluntarily nonsuited/dismissed. The first is a Governmental Tort Liability Act ("GTLA") case. Lynn v. City of Jackson, 63 S.W.3d 332, 337 (Tenn. 2001) (stating that the savings statute will not extend time in which an action must be filed under Tennessee's GTLA). The second type of case is a will contest action. In re Estate of Barnhill, 62 S.W.3d 139 (Tenn. 2001) (holding that a will contest action cannot be refiled after it has been voluntarily nonsuited/dismissed).
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