After the Covenant School shooting, public-records requests sought access to Metro Nashville’s investigative file, including the shooter’s writings. A trial court blocked disclosure entirely, but the Tennessee Court of Appeals rejected that blanket secrecy.

The court held that investigative files are generally public once an investigation ends, the school-security exception must be applied narrowly with redaction, and copyright or victims’ rights laws do not automatically prevent disclosure.

This decision clarifies how transparency and safety are balanced under Tennessee’s Public Records Act.

There are two types of methods by which a citizen may request records. The first type, a request to “inspect” (view) records, does not have to be in writing. Such a request may be in person, by phone, mail, email or portal if available. However, an entity may require a request to be in writing if the requestor is seeking copies of government records.

Official government business (see definition above), whether stored on a personal device or government device, is subject to TPRA. However, personal messages, even if on a government email account are not subject to public records request. So, what are districts to do with mixed messages. In short, the entity can redact the personal communications and produce that which is “concerning government business”.

Government transparency is essential for a strong democracy. To ensure such transparency, federal and state governments have passed legislation to provide citizens the right to copy or inspect records. Over the next month we will look at the laws governing open records in Tennessee.