Judicial Watch Announces Lawsuit Seeking Release of the ‘Manifesto’ of The Covenant School Shooter in Tennessee

(Washington, DC) – Judicial Watch today announced a public records lawsuit for records about the March 27, 2023, shooting at The Covenant School in Tennessee, including the reported “manifesto” written by the female shooting suspect. The suit is against the Metropolitan Government of Nashville and Davidson County in the Chancery Court for the State of Tennessee’s 20^th District. Judicial Watch filed the lawsuit on behalf of retired Hamilton County Sheriff James Hammond and the Tennessee Firearms Association, Inc. (“TFA”) (No. 23-0542-III).

On April 13, 2023, the TFA submitted two open records requests. The first request asked that the Metropolitan Nashville Police Department (“MNPD”) produce copies of records or files and inspection of “the ‘manifesto’ reportedly found in the home of Audrey Elizabeth Hall on March 27, 2023.”

The second request asked that the MNPD produce copies of records or files and inspection “all email communications of MNPD officials regarding the mass shooting committed by Audrey Elizabeth Hale on March 27, 2023, as well as MNPD officials’ text messages regarding the same, and copies of the ‘manifesto’ reported left by Audrey Elizabeth Hale in her vehicle.”

In a separate request on April 17, 2023, Hammond asked that the Metropolitan Nashville Police Department for:

1. All MNPD criminal police reports documenting this incident to include but not limited to:

a. Impound/evidence invoices

b. Photographs

c. Bodycam footage

d. City/County/State and/or federal coroner information

e. Suspect toxicology/lab results

f. Audio of calls for service

g. School video footage of suspect and officers

2. All MNPD Force Investigation Team (FIT) internal administrative investigations/reports regarding this incident to include but not limited to those mandated by The Manual of the Metropolitan Police Department of Nashville Davidson County, TN (the Department Manual) Title 1.130.050.

3. All MNPD communications, to include but not limited to directives, orders, memos, emails and/or letters, concerning the release of the contents and/or copies of the aforementioned “manifesto” of the deceased female shooting suspect.

4. All MNPD communications between the Federal Bureau of Investigation (FBI), the U.S. Department of Justice (DOJ), and/or the Office of the District Attorney, Nashville (20th Judicial District) regarding the designation of the aforementioned multiple shooting at a Christian School by a self-identified transgender suspect as a “hate crime.”

5. All MNPD criminal and/or field intelligence reports and/or received complaints involving the aforementioned shooting suspect (Audrey Hale) dated from January 1, 2020, to the date of your final response to this records request.

The MNPD denied all three requests citing without identifying any underlying criminal case or even a potential defendant.

The Tennessee Public Records Act states: “[a]ll state, county and municipal records shall… be open for personal inspection by any citizen of this state, and those in charge of the records shall not refuse such right of inspection to any citizen, unless otherwise provided by state law.” Tenn. Code Ann. § 10-7-503(a)(2)(A). The lawsuit requests the Court allow prompt access to the requested public records.

“Tennessee authorities have cited no credible reason for hiding the killer’s ‘manifesto’ about this deadly school shooting of three young children and three school employees,” stated Judicial Watch President Tom Fitton. “Politics shouldn’t trump transparency and the public safety. The public has an urgent right to know the details of this manifesto. That a public records lawsuit is required to try to access this key document is a scandal.”  

John I. Harris III, Esq., of Schulman, LeRoy & Bennett, PC in Nashville, TN, is assisting Judicial Watch with the lawsuit.  

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