JOHN COFFELT\
Editor

An attorney representing county UGB resident Sarah Bradley has filed a response and Motion for Judgement related to a Complaint for Injunctive Relief submitted to the Coffee County Circuit Court on July 16 by the City of Manchester.

The suit filed by the city asks the courts to prohibit Bradley from making public records requests for one year based on allegations of excessive and intentional misuse of the Public Records Act and accused her of willfully using records requests to disrupt governmental operations despite multiple warnings that she was doing so.

In response, Nashville-based attorney Daniel A. Horwitz, of Horwitz Law, said in the 31-page document, “A city deciding to sue one of its own citizens for keeping too close an eye on her government is an outrageous abuse of state power that should offend every decent member of society.  The City of Manchester for some reason wanted this fight, and it is going to get it good and hard.”

The counter complaint alleges the city’s suit is “a thin-skinned city government against a concerned citizen for asking too many questions.”

The suit said that Bradley, acting as an ordinary citizen, “exercised her statutory rights under the Tennessee Public Records Act to investigate how the City of Manchester runs its sewer system, spends federal grant money, disciplines its employees, and complies with environmental law.”

It alleges that “The City does not like being watched. Thus, upset with Ms. Bradley’s scrutiny of its conduct, it has sued her.”

“Ms. Bradley did not keep what she learned to herself, which has enraged the City and its officials. Instead, she reported to TDEC and the United States Environmental Protection Agency unreported sanitary sewer overflows into the Little Duck River and Old Stone Fort State Park, suspected Bonnaroo dumping, and unpermitted fill activity, and she urged the City to bring itself into compliance. She also shared documents with the press and public at large when she felt it was appropriate (or) necessary, sometimes prompting press coverage and strong public reaction that severely displeased the Mayor,” the suit further alleges.

Bradley’s Motion for Judgment says the city as the plaintiff is not “a records custodian” and cannot by state statute make the petition to the court.

It also said the city has not fulfilled the requisite steps before requesting relief, and that the disruptive intent that Bradley is accused of is under protective speech in addition to suggesting that the relief it seeks exceeds the statute.

Addressing the city’s allegations concerning claims that Bradley has shown a pattern of submitting voluminous record requests across multiple departments for records that far exceed the requirements listed under the Tennessee public records act, the countersuit denies the characterization of her requests as “numerous.”

Bradley “admits that her requests were not isolated requests seeking a single identifiable public record and contained multiple requests and that her November 17, 2023, request made 26 requests to the alleged departments and offices.”

She denies, however, the characterization of her requests as requesting “separate categories of records.”

Bradley admits that her November 17, 2025, request was properly submitted on a records request form and contained 50 requests as the June 15, 2026 request of 45 requests, and again denies the characterization of her requests as requesting “separate categories of records.”

The suit questions the city’s assertion that Bradley has exhibited “disruptive and aggressive behavior at governmental institutions and public organizations… and hostile and disruptive conduct toward city officials … including a verbally abusive conduct directed at a former Mayor (Marilyn Howard),” saying the City does not presently possess admissible evidence for them.

The suit asks the city’s injunction for relief be dismissed and the counter suit award Bradley “all nominal, compensatory, and incidental damages to which she is entitled; reasonable attorney’s fees and costs, her discretionary costs, pre-judgment and post-judgment interest and the city pay court costs.

The Mayor’s office was emailed for comment. The story will be updated if provided.

The Tennessee General Assembly added in 2021 a new subdivision in the public records law, T.C.A. 10-7-503(a)(7)(C). The new provision allows a government entity to petition a court for injunctive relief if a person requesting to view or receive copies of public records is making the request “with the intent to disrupt government operations.” This is the first attempt by a municipality to use the amendment in a suit.