On February 4, 2026, the Tennessee Court of Appeals entered a decision in favor of Bulso PLC clients Michael Leahy and Star News Digital Media Inc. on their claim under the Tennessee Public Records Act. In Brewer v. Metropolitan Government of Nashville and Davidson County, No. M2024-1139, the Court of Appeals reversed a decision by the Davidson County Chancery Court that had withheld from public disclosure essentially all records in Metro’s possession pertaining to the 2023 shooting at the Covenant School.
The Chancery Court, in an order entered July 4, 2024, had prohibited disclosure on three bases: Metro’s ongoing criminal investigation, a “school security” exception to the Public Records Act (found at Tenn. Code Section 10-7-504(p)), and the copyright interests in the shooter’s writings now held by a trust benefitting Covenant School students.
The Court of Appeals vacated the criminal-investigation ruling as moot, because Metro concluded and announced the findings of its criminal investigation in the summer of 2025; it ordered material withheld on that basis alone to be produced directly. It reversed the Chancery Court’s school-security ruling as an “overly broad, policy-based application application of” the statute and directed that only “information … regarding [Covenant’s] internal safety measures or plans” be withheld or redacted. And it reversed the Chancery Court’s ruling that the Copyright Act precluded disclosure of the shooter’s writings, both because the categorical determination that the works were copyrightable in full lacked an evidentiary basis and because “personal inspection” under the Public Records Act would not violate the Copyright Act. The Court of Appeals reversed and remanded for further proceedings.
In addition to Bulso PLC attorney Paul Krog, Mr. Leahy and Star News were represented by Nicholas Barry of America First Legal. The other appellants were represented by Richard Hollow of Knoxville, John Harris of Nashville, and Russ Nobile (senior attorney for Judicial Watch). Paul Krog argued for the appellants.
The appellees have sixty days to seek review in the Tennessee Supreme Court.
