South Dakota applies the discovery rule, which delays the beginning of the limitation period until the injury “occurred, became known or should have become known to the injured party.” Id.Statute of Repose: None.TennesseeStatute of Limitations: 1 year. Tenn. Code Ann. § 28-3-104. Tennessee applies the discovery rule, delaying accrual until the injury is discovered, or when in the exercise of reasonable care and diligence, it should have been discovered.
In most cases, the applicable statute of limitations is clear – one year for a personal injury claim (Tenn. Code Ann. § 28-3-104(1)), three years for a claim for injury to real or personal property (Tenn. Code Ann. § 28-3-105(1)), six years for a breach of contract claim (Tenn. Code Ann. § 28-3-109(3)), etc. – or at least undisputed by the parties. When the applicable statute of limitations is not clear or disputed by the parties, e.g. in cases involving alternative claims and requests for relief, Tennessee courts analyze “the basis for which damages are sought,” i.e. the “gravamen” analysis.
 Tenn. Code Ann. § 28-3-105(1). Tenn. Code Ann. § 28-3-104(c)(1). Tenn. Code Ann. § 28-3-110(a)(3).
Professional malpractice suits against licensed public accountants, certified public accountants, and attorneys must be filed within one (1) year after the accrual of the cause of action. Tenn. Code Ann. § 28-3-104(a)(2).[i] After July 1, 2014, these professional malpractice suits will also be subject to a five (5) year repose period, which begins to run “after the date on which the act or omission occurred.”