Tennessee Firearms Association Files Open Records Lawsuit Over Covenant School Shooter Manifesto

Image Credit: MNPD / Facebook

Press Release –

On May 1, 2023, James Hammond, former sheriff for Hamilton County, Tennessee, and the Tennessee Firearms Association, in cooperation with Judicial Watch, filed a lawsuit in the Chancery Court of Tennessee, Davidson County, against the Metropolitan Government of Nashville and Davidson County (“Metro”). ( A copy of the lawsuit is on the TFA’s news post) 

In the lawsuit, the parties ask for a court order to force Metro to turn over certain records as specified in the Petition related to the Covenant School shooting that occurred in March 2023.

In the two open records requests submitted by the Tennessee Firearms Association, TFA sought all records concerning the shooter’s “manifesto”. TFA also sought disclosure of “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.”

Sheriff Hammond, retired, submitted an additional open records request in which he requested:

Except as otherwise stated, the time frame for the requested records is for the period of March 27, 2023, to the date of your final response to this records request.

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.

Metro had denied all of these open records requests. Metro asserted that all three requests were “denied on the following grounds: The following state, federal, or other applicable law prohibits disclosure of the requested records: Open Case – Rule 16 of the Tennessee Rules of Criminal Procedure and Tennessean v. Metro. Gov’t of Nashville, 485 S.W.3d 857 (Tenn. 2016).”  However, the individual involved in the Covenant School shooting was killed by law enforcement on the day of the event. Metro failed to identify any pending criminal investigation that could even possibly result in criminal charges.

The lawsuit seeks a court order directing Metro to disclose the requested records and to pay the Plaintiffs’ their attorney’s fees.

Many believe that public access to these records is important for a number of reasons including the interest in determining the actual basis for the homicides particularly in light of Governor Bill Lee’s call for a special legislative session to consider his gun control proposal that he has presented in the format of a “Red Flag” law.