Tennessee Appeals Court Rules Covenant School Shooter's Writings Must Remain Accessible

Following the 2023 Covenant School shooting in Nashville, the shooter’s parents obtained the copyright to his manifesto and placed it in a trust for their children, arguing that the documents should not be disclosed. A lower court accepted that position, but the Tennessee Court of Appeals, in a decision authored by Judge Kristi Davis and joined by Judges John McClarty and Thomas Frierson, overturned it. The appellate panel clarified that the Tennessee Public Records Act obliges Metro Government of Nashville to permit personal inspection of the records, but does not require the city to copy or publish them.

The court emphasized that allowing inspection satisfies the statute while avoiding conflict with federal copyright law. It noted that any further use of the material by the requesters could expose them to copyright infringement liability, which the parents could still pursue. The ruling thus balances public-record access with the copyright holder’s remedies.