Can a Tennessee cow-share owner make and use butter from the cow's milk, and can the state charge a license fee for selling backyard-flock eggs?

Subject

Opinion No. 12-04, Owner's Use of Milk and Licensing of the Sale of Eggs, January 13, 2012

Plain-English summary

Representative Niceley asked two questions about the boundaries of Tennessee's farm-to-consumer exemptions.

Cow-share and dairy products. In 2009, the Tennessee General Assembly added Tenn. Code Ann. § 53-3-119 to allow an "independent or partial owner of any hoofed mammal" to use the animal's milk for the owner's personal consumption or other personal use, outside the Dairy Law's commercial regulatory framework. This is how Tennessee's cow-share and herd-share arrangements operate: you buy a share of a cow (or a goat or other hoofed mammal), pay boarding and care fees, and you get milk from "your" animal. The state's argument is that the milk never enters commerce, because you already own it.

Question 1 asks whether the § 53-3-119 exemption stretches to "dairy products" made from such milk (butter, cheese, yogurt) when consumed by the owner personally. The AG said yes. The phrase "other personal use" in § 53-3-119 reasonably covers making and consuming products derived from the milk. Statutory construction principles (Hayes v. Gibson County; State v. Flemming) support reading "personal use" naturally rather than artificially narrowly.

The opinion then narrows the door on the other side. "Partial owner" is undefined, and a sufficiently creative reader could argue that selling a slice of ownership (50 cents toward a share of the cow) with every $5 gallon of milk would convert any commercial milk sale into a "partial owner" arrangement and gut the Dairy Law's commercial regulation. The AG walked through legislative history (House Agriculture Committee testimony from Rep. Niceley himself, Rep. Bass, Adam Hill from TDA; Senate General Welfare Committee testimony from Sen. Faulk and Sen. Marrero) to show that the legislature intended a narrow exemption for genuine cow-share arrangements (boarding fees, ownership rights, personal consumption), not a workaround for commercial raw milk sales. Exceptions to general statutes are strictly construed (Anderson Fish & Oyster Co.; Metropolitan Development and Housing Agency v. Eaton).

The takeaway: § 53-3-119 protects authentic cow-share arrangements but cannot be used to evade the Dairy Law's commercial regulation. The exemption does not authorize the sale of milk or dairy products in the commercial marketplace.

Egg licensing and backyard flocks. Question 2 asks whether the TDA can charge a licensing fee on those who "sell only eggs produced by their own flocks." Tenn. Code Ann. § 53-2-107(2) reads: "No person shall buy, sell, trade, traffic or process eggs in this state without first having made application for and obtained a license as required by this chapter, with the following exceptions: ... (2) Those who sell only eggs produced by their own flocks."

The AG said: no, the TDA cannot impose a licensing fee on that group. The statute plainly exempts them from the licensure requirement. The TDA is an administrative agency (Tenn. Code Ann. § 4-3-101(1)) and cannot adopt rules that contradict legislative intent (Tennessee Department of Mental Health v. Allison).

But the AG also added two important qualifiers. First, "those" in § 53-2-107(2) refers back to "person," which the Egg Law defines broadly to include corporations, companies, partnerships, and associations (§ 53-2-102(4)). If the exemption were read broadly, a corporate egg producer with its own flocks could escape licensure entirely, and the rule would swallow itself. The AG read the exemption narrowly: it applies to small-scale own-flock sellers, not to commercial businesses. The TDA's longstanding interpretation along these lines deserves great weight (Covington Pike Toyota v. Cardwell). The General Assembly may need to clarify the line.

Second, exemption from licensure does not mean exemption from the rest of the Egg Law. Tenn. Code Ann. § 53-2-103 still prohibits selling inedible or adulterated eggs. The TDA still has authority to set egg standards and grades (§§ 53-2-104 to 106), labeling and candling requirements (§ 53-2-108), and extensive enforcement regulations (Tenn. Comp. R. & Regs. 0080-5-4-.01 to .21). All eggs in commerce, licensed seller or not, must comply.

Currency note

This opinion was issued in 2012. Subsequent statutory amendments, court decisions, or later AG opinions may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.

The raw-milk and cow-share landscape continues to evolve nationally. Tennessee's specific framework under § 53-3-119 may have been amended, and TDA enforcement priorities may have changed.

Background and statutory framework

The Dairy Law. Tenn. Code Ann. §§ 53-3-101 to 309. Enacted 1970 Tenn. Pub. Acts 577. Regulatory rules at Tenn. Comp. R. & Regs. 0080-03-01 to 07.

The cow-share exemption. Tenn. Code Ann. § 53-3-119 (added by 2009 Tenn. Pub. Acts Ch. 285): "Nothing in this part or any other provision of law shall be construed as prohibiting the independent or partial owner of any hoofed mammal from using the milk from such animal for the owner's personal consumption or other personal use."

The Egg Law. Tenn. Code Ann. §§ 53-2-101 to 115. Origins in 1951 Tenn. Public Acts 124 and 1955 Tenn. Public Acts 9, § 2. Regulatory rules at Tenn. Comp. R. & Regs. 0080-5-4-.01 to .21.

Egg licensing exemption. Tenn. Code Ann. § 53-2-107(2): "(2) Those who sell only eggs produced by their own flocks."

Egg Law safety/grading provisions that apply to everyone. § 53-2-103 (no sale of inedible or adulterated eggs); §§ 53-2-104 to 106 (TDA standards/grades, labeling/candling); § 53-2-108 (additional regulatory authority).

Definition of "person" under Egg Law. Tenn. Code Ann. § 53-2-102(4) includes individuals, corporations, companies, partnerships, associations.

Statutory construction principles. Hayes v. Gibson County, 288 S.W.3d 334, 337 (Tenn. 2009); State v. Flemming, 19 S.W.3d 195, 197 (Tenn. 2000); Leggett v. Duke Energy Corp., 308 S.W.3d 843, 851 (Tenn. 2010); Walker v. Sunrise Pontiac-GMC Truck, Inc., 249 S.W.3d 301, 309 (Tenn. 2008); State v. Edmondson, 231 S.W.3d 925, 927 (Tenn. 2007).

Exceptions strictly construed. Anderson Fish & Oyster Co. v. Olds, 197 Tenn. 604, 611, 277 S.W.2d 344, 347 (1955); Metropolitan Development and Housing Agency v. Eaton, 216 S.W.3d 327, 339-340 (Tenn. Ct. App. 2006).

Agencies cannot contradict statute. Tennessee Department of Mental Health v. Allison, 833 S.W.2d 82, 85 (Tenn. Ct. App. 1992).

Long-standing agency interpretation gets weight. Covington Pike Toyota, Inc. v. Cardwell, 829 S.W.2d 132, 134 (Tenn. 1992).

Plain meaning of clear statute. Graham v. Caples, 325 S.W.3d 578, 582 (Tenn. 2010).

Administrative department status. Tenn. Code Ann. § 4-3-101(1).

Common questions

Can a cow-share owner make cheese to give to friends?

The exemption covers "personal use." Giving cheese to friends might fit personal use; commercial sale (or sale through a co-op as a way around the regulation) would not. The AG didn't draw a sharp line on social sharing, but the legislative history makes clear the legislature did not intend to authorize commercial distribution.

Can a cow-share farm advertise its raw milk publicly?

The opinion did not directly address advertising. The legislative history suggests cow-share arrangements were envisioned as private agreements where the buyer comes to the farm, buys a share, and gets milk from the farm. Open public advertising to recruit "owners" could push the arrangement closer to a commercial milk sale that the Dairy Law regulates.

What if a backyard egg seller wants to sell at a farmers market?

The exemption applies if the seller sells only eggs from the seller's own flocks. Selling at a farmers market is allowed without a license. But the seller must comply with the Egg Law's safety, grading, candling, and labeling requirements, which the TDA enforces against all sellers.

What if I sell eggs from my flock plus eggs from a neighbor's flock?

That breaks the "only eggs produced by their own flocks" rule. Once a seller is moving any eggs not from the seller's own flock, the exemption no longer applies and the seller needs a license.

Does this opinion apply to milk shares from goats, sheep, or other hoofed mammals?

Yes. Section 53-3-119 says "any hoofed mammal." Goats and sheep are within the scope.

Can the TDA enforce safety rules against an exempt egg seller?

Yes. The exemption is from licensure only. All Egg Law safety, grading, candling, and labeling provisions apply to all eggs sold in commerce regardless of licensure status.

Citations

• Tenn. Code Ann. §§ 53-3-101 to 309
• Tenn. Code Ann. § 53-3-119
• Tenn. Code Ann. §§ 53-2-101 to 115
• Tenn. Code Ann. § 53-2-102(4)
• Tenn. Code Ann. § 53-2-103
• Tenn. Code Ann. §§ 53-2-104 to 106
• Tenn. Code Ann. § 53-2-107(2)
• Tenn. Code Ann. § 53-2-108
• Tenn. Code Ann. § 4-3-101(1)
• Tenn. Comp. R. & Regs. 0080-03-01 to 07
• Tenn. Comp. R. & Regs. 0080-5-4-.01 to .21
• 2009 Tenn. Pub. Acts Ch. 285
• 1955 Tenn. Public Acts 9, § 2
• 1951 Tenn. Public Acts 124
• 1970 Tenn. Pub. Acts 577
• Hayes v. Gibson County, 288 S.W.3d 334 (Tenn. 2009)
• State v. Flemming, 19 S.W.3d 195 (Tenn. 2000)
• Leggett v. Duke Energy Corp., 308 S.W.3d 843 (Tenn. 2010)
• Walker v. Sunrise Pontiac-GMC Truck, Inc., 249 S.W.3d 301 (Tenn. 2008)
• State v. Edmondson, 231 S.W.3d 925 (Tenn. 2007)
• Anderson Fish & Oyster Co. v. Olds, 197 Tenn. 604, 277 S.W.2d 344 (1955)
• Metropolitan Development and Housing Agency v. Eaton, 216 S.W.3d 327 (Tenn. Ct. App. 2006)
• Tennessee Department of Mental Health v. Allison, 833 S.W.2d 82 (Tenn. Ct. App. 1992)
• Covington Pike Toyota, Inc. v. Cardwell, 829 S.W.2d 132 (Tenn. 1992)
• Graham v. Caples, 325 S.W.3d 578 (Tenn. 2010)
• Hearing on H.B. 720 before the House Agriculture Committee, 2009 Leg., 106th General Assembly (April 21, 2009)
• Hearing on S.B. 1114 before the Senate General Welfare Committee, 2009 Leg., 106th General Assembly (April 29, 2009)

Source

• Landing page: https://www.tn.gov/attorneygeneral/opinions.html
• Original PDF: https://www.tn.gov/content/dam/tn/attorneygeneral/documents/ops/2012/op12-004.pdf

Original opinion text

January 13, 2012
Opinion No. 12-04
Owner's Use of Milk and Licensing of the Sale of Eggs

QUESTIONS

1. Can an "independent or partial owner of any hoofed mammal" use a dairy product made from the milk produced by such animal for the owner's personal consumption or other personal use?

2. Does the Tennessee Department of Agriculture ("TDA") have the legal authority to impose a licensing fee on those who "sell only eggs produced by their own flocks"?

OPINIONS

1. Yes, an "independent or partial owner of any hoofed mammal" may use a dairy product made from the milk produced by such animal for the owner's personal consumption or other personal use. However, this exemption from the regulatory standards established by Tennessee's Dairy Law does not permit the sale of such milk or dairy products in the commercial marketplace.

2. No, the TDA does not have the legal authority to impose a licensing fee on those who "sell only eggs produced by their own flocks." This exemption from licensure should be narrowly construed in consideration of the remedial and public safety purposes of the Tennessee Egg Law. This exemption does not relieve persons selling eggs in the commercial market from compliance with the Egg Law's regulatory safeguards.

ANALYSIS

This opinion request addresses a provision of the Dairy Law of the State of Tennessee, enacted in 1970 (hereinafter "Dairy Law"). Tenn. Code Ann. §§ 53-3-101 to 309. See also 1970 Tenn. Pub. Acts 577. The Dairy Law, among other things, regulates the production and sale of dairy products to ensure that such products are safe for human consumption. Tenn. Code Ann. §§ 53-3-101 to 119; Tenn. Comp. R. & Regs. 0080-03-01 to 07 (2011).

The Tennessee General Assembly in 2009 enacted legislation to allow an "independent or partial owner of any hoofed mammal" to use milk produced by the animal for the owner's personal consumption or other personal use. 2009 Tenn. Pub. Acts Ch. 285. This legislation exempted milk so used from the regulatory requirements set forth in the Dairy Law. The statute provides:

Nothing in this part or any other provision of law shall be construed as prohibiting the independent or partial owner of any hoofed mammal from using the milk from such animal for the owner's personal consumption or other personal use.

Tenn. Code Ann. § 53-3-119.

The question presented is does this statute also apply to a "dairy product" made from such milk, which is used for the owner's personal consumption or other personal use. When construing a statute, the primary goal of the courts is to give effect to the purpose of the legislation without exceeding its intended scope. Hayes v. Gibson County, 288 S.W.3d 334, 337 (Tenn. 2009). Legislative intent is determined from the natural and ordinary meaning of the statutory language within the context of the entire statute, without adopting any forced or subtle construction that would extend or limit the statute's meaning. State v. Flemming, 19 S.W.3d 195, 197 (Tenn. 2000).

The statute in question permits milk from a hoofed mammal to be used by the owner for personal consumption or other personal use. In considering the natural and ordinary meaning of the term "other personal use," it is our opinion this term should be reasonably construed to include allowing an independent or partial owner to use a dairy product made from the milk produced by such animal for his or her personal consumption or use.

In so finding, this Office observes the General Assembly intended the exemption for "partial owners" of hoofed animals to be narrowly construed. The term "partial owner" is not defined by this statute. Thus conceivably an argument might be made that innumerable partial interests in a mammal or mammals could be included in the commercial sales price of milk or milk products from those mammals, thereby allowing the seller of milk or milk products to use this exemption to entirely avoid compliance with Tennessee's regulatory framework designed to ensure the safe production and consumption of milk and related dairy products in the commercial marketplace.

In this case, where the definition of "partial owner" is unclear and subject to various interpretations, the statute's meaning is to be ascertained by examining the broader statutory scheme as well as the history of the legislation. See Leggett v. Duke Energy Corp., 308 S.W.3d 843, 851 (Tenn. 2010); Hayes v. Gibson County, 288 S.W.3d 334, 337 (Tenn. 2009). An examination of these relevant sources affirms that the term "partial owner" in Tenn. Code Ann. § 53-3-119 should be narrowly construed.

First, the legislative history of Chapter 285, which was enacted as Tenn. Code Ann. § 53-3-119, reveals that the personal use or consumption of milk from the "partial" ownership of hoofed mammals was to be limited to persons who would go to farms selling such milk and buy the milk as well as a share of the mammal producing such milk. The following testimony before the House Agriculture Committee confirms this intent:

Rep. Bass: Thank you Mr. Chairman, how many people can own a part of a cow?

Rep. Niceley: Rep. Litz says hundreds. Just like a race horse or anything else. But I could say the good thing about the way and the Department of Agriculture brought me this version and other states do it this way and a good thing about this is the person buying the milk knows the cow, knows the farm, has to go to the farm to buy it and is familiar with the level of management and is comfortable with it and the good thing about it, it keeps the consumer coming to the farm and the farmer gets full retail. What's hurting the farming industry is the middle man is making all the money and the farmer is not getting the retail but doing it this way the consumer comes to the farm pays full retail which is a tremendous eight times what they would get if they would be selling it wholesale. And then once you get them there you may sell them something else. You may sell them some vegetables or eggs or one thing or another and you know it's not a big thing. I like to look at it like it's a micro dairy just like the micro breweries and the micro distilleries. I like to look at this like it's a micro dairy. Does that answer your question?

Rep. Bass: Well, I guess what I am asking is can they set up shop selling raw milk and when they say using a number $5 gallon of milk is 50 cents of that going for part ownership in a cow and then that way they can be open from now on just to sell it wide open? Do I make sense?

Rep. Niceley: I guess a devious mind could probably pervert this somehow and you seem to have one.

Rep. Bass: Well, I think the author of this amendment had one that's the reason I'm asking.

Rep. Niceley: Actually, this amendment is the way they do it in other states and they don't have any problems. I think you know once it's been tested out that's a good thing about all these other states. These other states are laboratories that test things out and this has been tested out and seems to be working pretty good.

Rep. Bass: Thank you. Thank you, Mr. Chairman.

Chairman Bone: Do we have any comment from anybody or from the department? Do either one of you gentleman like to make a statement I know you've seen the amendment.

Adam Hill: Chairman, members of the committee. Adam Hill Department of Agriculture. We worked with the sponsor on the amendment and think it's gonna be ok.

. . .

Rep. Bass: Mr. Hill- same question to you that was asked to Mr. Niceley. So the department wouldn't have any problem with the scenario I presented?

Adam Hill: Sure.

Rep. Bass: You said no.

Adam Hill: Could you remind me of the scenario?

Rep. Bass: You go the farm you buy $5 gallon of milk and also 50 cents of that goes to your ownership of the cow, partial ownership of the cow, but that's ok?

Adam Hill: The way I understand this to work is that you enter into an agreement with a farmer and you would pay like a boarding fee and you'd pay an annual fee for the upkeep of that animal whatever they have to do you know feeding it and caring for the animal and as the owner of that cow you would enjoy all rights of ownership that milk or if it went to slaughter any ownership rights that you would have and that's consistent with where the department's position is on it. I think it helps encourage people to buy more cattle which is definitely something that would be good for the cattle industry.

Hearing on H.B. 720 before the House Agriculture Committee, 2009 Leg., 106th General Assembly (April 21, 2009) (emphasis added).

The following testimony before the Senate General Welfare Committee assured that this exemption would not permit milk or milk products subject to the exemption to be sold to the general public in the commercial marketplace:

Sen. Faulk: Thank you, Mr. Chairman. The bill as it currently exists now simply says that there is nothing in our dairy law that is to be construed that prohibits the independent or partial owning of a hoofed animal from using that milk for the owner's personal consumption or other personal use.

Chairman Watson: Members, you've seen the amendment. Are they any questions? Senator Marrero.

Sen. Marrero: I am a little bit confused about this. Are they going to sell this raw milk or are they going to consume this raw milk on the premises?

Sen. Faulk: Consume.

Sen. Marrero: And it's just for the people around...

Sen. Faulk: It's for the owner or partial owner of any hoofed animal.

Sen. Marrero: Ok. So, but they won't be, this is not something they'll be selling to the general public?

Sen. Faulk: Not under this bill.

Hearing on S.B. 1114 before the Senate General Welfare Committee, 2009 Leg., 106th General Assembly (April 29, 2009) (emphasis added).

The broader regulatory scheme of the Tennessee Milk Act, which is designed to protect consumers in the commercial marketplace from the production and sale of unsafe milk, further supports a narrow construction of this exemption. As confirmed by the aforementioned legislative history, the General Assembly did not intend this limited exemption to be used by individuals or entities to totally circumvent the laws designed to ensure the safe production and consumption of milk and other dairy products derived from milk. Such an expansive interpretation would be contrary to the overall intent of the Dairy Law to protect consumers from unsafe milk or milk byproducts. Indeed a narrow construction of the term "partial owner" in this context is in accord with the well-established rule of statutory construction that courts interpreting statutes must look to the object and reach of the entire statutory framework, the wrong or evil which it seeks to remedy or prevent, and the purpose sought to be accomplished by its enactment. See Walker v. Sunrise Pontiac-GMC Truck, Inc., 249 S.W.3d 301, 309 (Tenn. 2008); State v Edmondson, 231 S.W.3d 925, 927 (Tenn. 2007). Absent the existence of a clear legislative intent to allow this exemption to significantly alter the long existing regulation of those selling dairy products in Tennessee's commercial marketplace, the exemption should be confined to those persons who own an interest in a mammal, intend to use the milk or dairy product from the mammal for their own personal use, and are not engaged in the actual sale of such milk in the commercial marketplace. See Anderson Fish & Oyster Co. v. Olds, 197 Tenn. 604, 611, 277 S.W.2d 344, 347 (1955); Metropolitan Development and Housing Agency v. Eaton, 216 S.W.3d 327, 339-340 (Tenn. Ct. App. 2006) (both cases noting that an exception to a general statute is strictly construed).

You next ask whether the TDA has the legal authority under the Tennessee Egg Law to impose a licensing fee on those who "sell only eggs produced by their own flocks." See Tenn. Code Ann. §§ 53-2-101 to 115. The TDA is an administrative department created and established by the legislature. Tenn. Code Ann. § 4-3-101(1). An administrative department has the authority to implement statutes but may not adopt rules or policies that contradict the intent of the legislature. Tennessee Department of Mental Health v. Allison, 833 S.W.2d 82, 85 (Tenn. Ct. App. 1992).

The licensing exemption at issue under the Egg Law states in pertinent part:

No person shall buy, sell, trade, traffic or process eggs in this state without first having made application for and obtained a license as required by this chapter, with the following exceptions: . . .

. . .

(2) Those who sell only eggs produced by their own flocks.

Tenn. Code Ann. § 53-2-107(2).

This language plainly states that those who sell only eggs produced by their own flocks are exempt from the requirement of applying for and obtaining a license; thus the imposition of a "licensing fee" on such producers is contrary to the plain language and clear legislative intent of the statute. See Hayes v. Gibson County, 288 S.W.3d at 337. Therefore, the TDA does not have the requisite authority to impose a licensing fee on those who sell only eggs produced by their own flocks.

However, this exemption from licensure under the Egg Law is limited to a narrow group of egg sellers and does not relieve those sellers from the regulatory requirements of the Egg Law. The word "those" in Section 53-2-107(2) apparently refers to "persons," which is defined broadly under the Egg Law to include not only individuals but also corporations, companies, partnerships and associations. Tenn. Code Ann. § 53-2-102(4). Thus conceivably this exception could swallow the rule requiring licensure, given a large corporation could own substantial flocks from which it is selling eggs to the public. However, it is doubtful the General Assembly intended such a result given the Egg Law's clear intent to create a licensure and regulatory framework to ensure the safe production of eggs sold at retail to the general public. Tenn. Code Ann. §§ 53-2-102 to 111 (2008 and Supp. 2010). See also 1955 Tenn. Public Acts 9, § 2; 1951 Tenn. Public Acts 124. A narrow interpretation of this exemption conforms with the established rule of statutory construction that courts, when interpreting a statute, will look to the entire purpose of the statutory framework as well as the wrong or evil it seeks to remedy or prevent. See Walker v. Sunrise Pontiac-GMC Truck, Inc., 249 S.W.3d at 309; State v. Edmondson, 231 S.W.3d at 927. This Office also understands the TDA has long interpreted this licensure requirement in this manner. Such a well established interpretation is entitled to great weight in determining the intention of the legislature, especially where the interpretations are unchallenged over a long period of time. Covington Pike Toyota, Inc. v. Cardwell, 829 S.W.2d 132, 134 (Tenn. 1992). Accordingly this exemption from licensure should be limited in its application to those individuals engaged in relatively small sales of eggs from their own flocks and not be deemed applicable to those persons selling eggs as a commercial business. See also Anderson Fish & Oyster Co. v. Olds, 227 S.W.2d at 347 (holding that exceptions to a general statute should be strictly construed). This of course in some instances may be a difficult distinction to make, and the General Assembly may choose at some point to clarify the limits of this exemption.

Furthermore, a person's exemption from licensure does not exempt that person from complying with the Egg Law's salutary regulatory requirements designed to ensure the production and sale of safe eggs. The Egg Law prohibits any person from selling or attempting to sell inedible or adulterated eggs for human consumption. Tenn. Code Ann. § 53-2-103. The TDA likewise has authority to establish standards and grades for all eggs sold in the commercial market in order to protect the public health and welfare, as well as to restrict the advertising or sale of all fresh eggs and to ensure statutory labeling and candling requirements for all eggs sold in the commercial market. Tenn. Code Ann. §§ 53-2-104 to 106, 53-2-108. The TDA has adopted extensive regulations to enforce these statutes and thereby protect customers from the sale of eggs unfit for human consumption. Tenn. Comp. R. & Regs. 0080-5-4-.01 to .21 (2011). These regulatory provisions by their express terms apply to all eggs sold in the commercial marketplace, regardless whether the person selling the eggs is licensed. See Graham v. Caples, 325 S.W.3d 578, 582 (Tenn. 2010) (finding that the plain and ordinary meaning of a statute must be given full effect if the language is not ambiguous).

ROBERT E. COOPER, JR.
Attorney General and Reporter

WILLIAM E. YOUNG
Solicitor General

DIANNE STAMEY DYCUS
Deputy Attorney General

Requested by:
Honorable Frank Niceley
State Representative
108 War Memorial Building
Nashville, TN 37243-0117