The City of Manchester has filed for an injunction against resident Sarah Bradley over her records requests, saying her requests were made with “an intent to disrupt government operations.” The injunction seeks to prevent Bradley from making requests for one year.

The filing is believed to be the first in Tennessee against a public records requester using T.C.A. § 10-7-503 (a)(2)(C). (See below for a copy of the entirety of this provision.)

The law, passed in 2021, allows a court to enjoin the person from making additional requests for up to one year upon finding by clear and convincing evidence that the person’s requests were made with the intent to disrupt government operations.

The city contends that Bradley’s intent to disrupt government operations “may be inferred” through Bradley’s repeated submission of records requests after she was warned about “the use of broad categories rather than discrete identifiable records, the inclusion of requests seeking explanations, or information rather than existing records, and the repeated demand that City employees search across multiple departments, and require City employees to publish the requested records on the city website, making substantially more work for City employees and department heads.”

“The city does not contend that requesting public records, standing alone, constitutes disruptive conduct. Rather, the Plaintiff alleges that the Defendant’s repeated pattern of submitting exceptionally broad, multi-department requests, requesting publication of records to the City’s website, requesting explanations rather than identifiable records, repeatedly changing or abandoning requests after substantial staff work has been performed, and continuing the same conduct after multiple written warnings collectively demonstrates an intent to disrupt government operations,” according to the complaint filed Friday, July 17. (City of Manchester v. Sarah Bradley).

The attorney for the city is L. Craig Johnson of Manchester. So far, no attorney has been listed in the court for Bradley. The judge assigned to the case is Circuit Court Judge William Lockhart. The Manchester records custodian involved is Anthony Burrows.

On July 7, the Manchester Board of Mayor and Aldermen voted against a motion by Alderman Julie Anderson to enter into mediation with Bradley through the Office of Open Records Counsel in the Tennessee Comptroller’s Office. Earlier in the meeting, Bradley during public comment asked the city to agree to mediation provided free by the office, which she said she has asked for before.

In its petition, the city lists public records requests beginning Aug. 22, 2023. These consist of two requests in 2023, six requests in 2024, three in 2025 and two in 2026. The city emphasized that each of the requests sought multiple records.

Some of the records listed by the city appear mundane and conceivably easy to retrieve, such as minutes of public meetings, monthly operation reports for the wastewater treatment plant, monthly director reports for departments, inspection reports and long-term capital plans and Economic Development Administration grant proposals.

Others were specific to sewer, such as inflow and infiltration reduction data, flow addition data to the sewer system, sewer overflow monitoring policies and procedures, sewer overflow manhole inspection checklists, sewer overflow tracking data and directors reports for the Mayor and Water and Sewer Commission.

The city described the requests, however, as requests for “broad categories rather than identifiable records, including ‘emails regarding’ a public body, ‘monthly director reports for all departments,’ ‘long-term capital plans for all departments’ and ‘any/all 2025 meetings’ for certain boards and commissions.”

The city did not mention if it denied any requests based on not being specific enough to enable identification of the records requested. Nor did it indicate if Bradley paid for copies of records during this period. The city made note of Bradley’s request that it records on the website that she “reasonably believed to be of general public interest,” saying this request “sought to impose impose additional work on City employees beyond simply making responsive public records available to the requester.”

The complaint for injunctive relief emphasized “numerous hours have been expended searching for the requested records.” The only hours documented in the initial complaint was for a November 2023 request that the city said required three hours and another, which the city did not identify by date, that required 15 hours of staff labor.

The city recorder, Lisa Myers, issued the first written warning to Bradley on Dec. 28, 2023, noting “five requests” though only two requests were listed in the petition for 2023.

The statutory process allowing a records custodian to petition a court for an injunction has no limit on the number of requests that a Tennessee citizen can make to a government entity, and neither does any other part of the Tennessee Public Records Act.

The “five requests” likely comes from the provision to seek an injunction. It says that a custodian cannot petition the court for relief until the custodian has warned the requester of the “specific conduct that may constitute intent to disrupt government operations” and that it may provide such notification after the “fifth request by the person made with intent to disrupt government operations.”

A second written warning in 2025 identified six requests received in 2024 and the two in 2025 that the city said were “ambiguous, voluminous in nature and … required numerous hours of unjustified and unreimbursed work…” It also said the city has searched for records “only to have the Defendant change her mind and withdraw the requests after numerous hours have been expended search for the requested records.”

The city says that Bradley’s continued submission of public records requests, including one in November 2025, one in June 2026 and one in July 2026 “supports the inference that the disruption is not accidental, isolated or incidental.”

“The Defendant was expressly advised that her conduct was disrupting City operations, and that continued conduct could result in an injunction, yet she continued submitting the same type of voluminous and multipart requests.”

The city also filed “Plaintiff’s First Set of Interrogatories Propounded to Defendant Sarah Bradley” with questions they ask to be produced within 30 days.

Here is the statute governing the process, T.C.A. § 107-503(a)(2)(C):

(C)

(i) If a person makes a request to view or copy a public record with the intent to disrupt government operations, the records custodian charged with fulfilling the request may petition a court of record of competent jurisdiction for an order to enjoin the person from making records requests.

(ii) A records custodian shall not petition a court for injunctive relief unless the records custodian has notified the person making the requests in writing stating the specific conduct that may constitute intent to disrupt government operations in violation of this subdivision (a)(7)(C) and the person has continued to engage in such conduct after the notification. The records custodian shall provide such notification after the fifth request by the person made with intent to disrupt government operations.

(iii) After a petition is filed and while the case is pending, the records custodian shall continue to comply with this part, but if the records custodian prevails, the person making the requests shall reimburse the records custodian for the labor costs incurred by the records custodian in producing the records during the pendency of the case.

(iv) A court may, upon finding by clear and convincing evidence that a records request was made with intent to disrupt government operations, enjoin the person who made the request from making a public records request for a period of up to one (1) year; provided, that the person, while subject to the injunction, may petition the same court for permission to make a public records request and the court may approve the petition if the petitioner shows that the public records request is not made with intent to disrupt government operations.

(v) A records custodian who petitions a court for an injunction pursuant to this subdivision (a)(7)(C) shall provide a written report to the office of open records counsel that includes a copy of the petition and any injunction or orders issued by the court. The report must be filed no later than three (3) months after the petition is filed. If a final order has not been issued within three (3) months of the petition’s filing, the records custodian shall provide the final order to the office of open records counsel as soon as reasonably possible after the final order is issued. The office of open records counsel shall include a summary of the reports received as part of the office’s annual report required by § 8-4-603(b) and provide the summary to the advisory committee on open government.