Can an elected Tennessee municipal court clerk set bail for arrested defendants, even when the municipal court has concurrent jurisdiction with general sessions?

Subject

Whether an elected municipal court clerk has authority to admit a defendant to bail under Tenn. Code Ann. § 40-11-105(a) or any other general law, even when the municipal court exercises concurrent jurisdiction with a general sessions court.

Plain-English summary

Representative Esther Helton-Haynes asked a very specific question: when a Tennessee city's municipal court has been given concurrent jurisdiction with a general sessions court, does the elected clerk of that municipal court have power to admit a defendant to bail like a circuit or criminal court clerk does? The AG's answer is no.

Section 40-11-105(a) of the Bail Reform Act of 1978 enumerates exactly three categories of officials who can admit a defendant to bail: committing magistrates, judges of circuit and criminal courts, and clerks of circuit and criminal courts. The AG walks each category and shows that an elected municipal court clerk fits none.

A municipal court clerk is not a circuit or criminal court clerk. The Bail Reform Act elsewhere uses the phrase "city court clerk" (in §§ 40-11-107 and 40-11-108) when it wants to give those clerks authority. The legislature also uses other phrasings ("clerk of the court having jurisdiction of the offense," "clerk of the court before which the proceeding is pending") when it intends to reach a broader set of clerks. Section 40-11-105(a) uses the narrow phrase "clerk of any circuit or criminal court," and that drafting choice is read as deliberate exclusion of city court clerks. State v. Casper and Crowe v. Ferguson supply the construction principle.

A municipal court clerk is not a magistrate either. Title 40 defines "magistrate" to mean three groups: judges of the supreme, appellate, chancery, circuit, general sessions, and juvenile courts; judicial commissioners and county mayors; and the presiding officer of any municipal or city court. The first two clearly do not include a municipal court clerk. The third (presiding officer) refers to the city judge, not the clerk; case law (State v. Ford) confirms it. The 1973 Public Acts that added the "presiding officer" clause was titled an act to include "judges of municipal courts" within the magistrate definition, and the legislative history confirms the same.

Concurrent jurisdiction with general sessions does not change the answer. Section 18-4-203 lets a general sessions court clerk set bond when the judge is absent, but that statute applies to general sessions clerks, not municipal court clerks who happen to serve a municipal court with concurrent general sessions jurisdiction. The concurrent-jurisdiction grant in § 40-1-107 reaches the municipal court (the judge), not the clerk. When the legislature wants to give municipal court clerks general sessions clerk powers, it does so explicitly (e.g., § 6-54-303 for issuing execution); § 18-4-203 does not.

Finally, setting bail is a judicial act, not a ministerial one. Section 40-11-118(b) lists discretionary factors a court considers when fixing bail. Discretionary acts cannot be delegated to a ministerial officer like a clerk. Even if the legislature wanted to give a clerk this power, it would have to say so expressly.

The remaining three questions in the request (limits on the authority, the judge's power to limit it, and oversight bodies) are all moot because the clerk has no such authority to begin with. The opinion notes a single carve-out: a Private Act could authorize a particular municipal court clerk to set bail. General law does not.

What this means for you

If you are a municipal court clerk currently setting bail

Stop, unless you have express authority under a Private Act applicable to your court. The AG's analysis is unambiguous: no general statute authorizes you to admit a defendant to bail. If your office's local practice has been for the clerk to set bail when the judge is unavailable, that practice is unauthorized. Coordinate with your municipal judge and city attorney to revise the procedure: the judge sets bail, or a magistrate (a committing magistrate as defined in § 40-1-106), or a circuit or criminal court clerk under the conditions of § 40-11-105(a)(2).

If you are a municipal court judge

You cannot delegate bail-setting to your clerk. The AG cites the standard rule that judicial functions cannot be delegated to ministerial officers. Coordinate with the chief of police, jailer, magistrate, judicial commissioner, or county sheriff so a person with statutory authority is reachable when defendants are arrested. If your municipality wants to give the clerk this authority, the path is a Private Act.

If you are a city attorney advising a municipality

Audit local practice. If the clerk has been setting bail, identify the source of authority. If the only source is local practice, the practice has to change. The Private Act path is available if the city wants to give clerk-set-bail authority by formal action of the General Assembly applicable to that municipality.

If you are a defendant or defense attorney facing a bail set by a municipal court clerk

The bail order may be procedurally defective. The AG opinion is persuasive authority that an elected municipal court clerk lacks general-law authority to set bail. Contesting the bail order on this ground is plausible. Note the Private Act caveat: check whether a Private Act applies to that particular municipality's court.

If you are a bail bondsman or jailer

Confirm that bail is set by an authorized official before processing release. The Bail Reform Act gives sheriffs and peace officers a specific deposit duty under § 40-11-106(a) (deposit with "the clerk of the court having jurisdiction of the offense"). The deposit step is procedurally distinct from the admit-to-bail step.

If you are a state legislator

If giving municipal court clerks bail-setting authority would help process intake, the AG opinion is the roadmap. The legislature would have to amend § 40-11-105(a) to add municipal court clerks (or a defined subset) explicitly. Until then, only Private Acts can grant the authority for specific cities.

Common questions

Q: Even with concurrent general sessions jurisdiction?
A: Even then. The concurrent jurisdiction grant runs to the court (the judge), not the clerk. The general sessions clerk's bail authority under § 18-4-203 does not transfer to a municipal court clerk by virtue of the court's expanded jurisdiction.

Q: What about a Private Act?
A: A Private Act can authorize a specific municipal court clerk to set bail. The opinion expressly notes this carve-out (footnote 11).

Q: Who can set bail under § 40-11-105(a)?
A: (1) committing magistrates as defined in § 40-1-106; (2) judges of circuit and criminal courts; and (3) clerks of circuit and criminal courts (only when the judge is not present and the clerk reasonably believes the judge will not be present within three hours after the defendant has been committed to the county or city jail).

Q: Who counts as a committing magistrate?
A: Per § 40-1-106: judges of the supreme, appellate, chancery, circuit, general sessions, and juvenile courts; judicial commissioners and county mayors in those officers' respective counties; and the presiding officer (i.e., the judge) of any municipal or city court within the limit of their respective corporations.

Q: Why isn't a municipal court clerk a "presiding officer" of the municipal court?
A: Case law (State v. Ford) and AG opinions (84-228, 78-365) treat city court judges as the presiding officers. The 1973 legislative history of § 40-1-106 specifically references "judges of municipal courts," not clerks.

Q: Why is bail-setting a judicial function?
A: Section 40-11-118(b) requires the court to consider a list of discretionary factors when fixing bail. State v. Melson (Tenn. 1982) and State ex rel. Millers Nat'l Ins. Co. v. Fumbanks (Tenn. 1941) frame the act as discretionary and judicial. Discretionary acts cannot be delegated to ministerial officers (clerks).

Q: Can the clerk "take" bail (collect the bond) once it's set?
A: Yes. Sections 40-11-107 and 40-11-108 specifically address the authority of "the city court clerk" to "take" bail. Taking bail (accepting the deposit after the judge has set the amount) is a ministerial act and is permitted. Setting the amount is the prohibited part.

Background and statutory framework

Tennessee criminal defendants have a constitutional right to bail before trial except in capital cases. Tenn. Const. art. I, § 15; Wallace v. State (1952); Tenn. Code Ann. § 40-11-102. The Release from Custody and Bail Reform Act of 1978 (Tenn. Code Ann. § 40-11-101 et seq.) is the statutory framework.

Section 40-11-105(a)(1) lists three categories of officials authorized to admit a defendant to bail: committing magistrates; judges of circuit or criminal courts; and clerks of circuit or criminal courts. Subsection (a)(2) limits the third category: a clerk may admit only when the judge is not present and the clerk reasonably believes the judge will not be present within three hours after the defendant is committed.

The "magistrate" category in title 40 is defined in § 40-1-106 and includes judges of the supreme, appellate, chancery, circuit, general sessions, and juvenile courts; judicial commissioners and county mayors in their respective counties; and the presiding officer (judge) of any municipal or city court. The 1973 amendment that added the third group expressly referred to "judges of municipal courts."

The "clerk of any circuit or criminal court" category is defined by reference to circuit and criminal courts under § 16-10-101 et seq., with clerks elected under § 18-4-101. The Bail Reform Act elsewhere uses different language when it wants to reach a broader set of clerks ("clerk of the court having jurisdiction of the offense" in § 40-11-106(a); "clerk of the court before which the proceeding is pending" in § 40-11-118(a)(1)). City court clerks are explicitly named as authorized to "take" (i.e., accept) bail under §§ 40-11-107 and 40-11-108. The legislature's choice to use the narrow phrase in § 40-11-105(a) excludes city court clerks from the admit-to-bail category. Casper, Crowe.

Section 18-4-203 authorizes a general sessions court clerk to set bond in the judge's absence. The statute does not extend by analogy to municipal court clerks even when the municipal court has concurrent general sessions jurisdiction. Concurrent jurisdiction is conferred via § 40-1-107 on city judges, not clerks. When the legislature wants to give municipal court clerks general sessions clerk powers, it does so explicitly (§ 6-54-303 for execution on judgments).

Setting bail is a judicial function because it requires discretion and judgment. § 40-11-118(b) lists factors. State v. Melson (Tenn. 1982); State ex rel. Millers Nat'l Ins. Co. v. Fumbanks (Tenn. 1941). Judicial functions cannot be delegated to ministerial officers (clerks) absent express statutory authorization.

A Private Act could authorize a particular municipal court clerk to set bail (footnote 11). General law does not.

Citations

Constitutional and statutory provisions:
- Tenn. Const. art. I, § 15
- Tenn. Code Ann. §§ 40-11-101 et seq. (Bail Reform Act of 1978)
- Tenn. Code Ann. § 40-11-102 (right to bail)
- Tenn. Code Ann. § 40-11-105(a) (admit-to-bail authority)
- Tenn. Code Ann. § 40-11-106(a), (b)(1)
- Tenn. Code Ann. §§ 40-11-107, 40-11-108 (city court clerks taking bail)
- Tenn. Code Ann. § 40-11-118(a)(1), (b)
- Tenn. Code Ann. §§ 40-11-119, 40-11-120, 40-11-122
- Tenn. Code Ann. § 40-1-106 (magistrate definition)
- Tenn. Code Ann. § 40-1-107 (concurrent jurisdiction)
- Tenn. Code Ann. § 40-1-111; § 40-5-201 to -204 (judicial commissioners)
- Tenn. Code Ann. § 16-10-101 et seq.
- Tenn. Code Ann. § 16-18-310
- Tenn. Code Ann. §§ 18-1-105, 18-1-108
- Tenn. Code Ann. § 18-4-101
- Tenn. Code Ann. § 18-4-203
- Tenn. Code Ann. § 6-54-303

Cases:
- Wallace v. State, 245 S.W.2d 192 (Tenn. 1952), right to bail
- Bailey v. Schubert, 315 S.W.2d 249 (1958), clerk as ministerial officer
- State v. Casper, 297 S.W.3d 676 (Tenn. 2009), purposeful inclusion/exclusion canon
- Crowe v. Ferguson, 814 S.W.2d 721 (Tenn. 1991), same
- State v. Ford, 2008 WL 1968824 (Tenn. Ct. App. 2008), city court judge as presiding officer
- Womack v. Corrections Corp. of Am., 448 S.W.3d 362 (Tenn. 2014), caption and legislative history
- State ex rel. Millers Nat'l Ins. Co. v. Fumbanks, 151 S.W.2d 148 (Tenn. 1941), judicial vs. ministerial
- State v. Melson, 638 S.W.2d 342 (Tenn. 1982), wide latitude in setting bail
- City of McMinnville v. Hubbard, 2019 WL 719077 (Tenn. Crim. App. 2019), concurrent jurisdiction
- State v. Paster, 2015 WL 376450 (Tenn. Crim. App. 2015), same

Prior AG opinions cited:
- Tenn. Att'y Gen. Op. 78-365 (Oct. 6, 1978)
- Tenn. Att'y Gen. Op. 84-228 (July 24, 1984)
- Tenn. Att'y Gen. Op. 99-008 (Jan. 25, 1999)
- Tenn. Att'y Gen. Op. 03-110 (Sept. 8, 2003)
- Tenn. Att'y Gen. Op. 05-018 (Feb. 4, 2005)
- Tenn. Att'y Gen. Op. 08-136 (Aug. 15, 2008)

Source

• Landing page: https://www.tn.gov/attorneygeneral/opinions.html
• Original PDF: https://www.tn.gov/content/dam/tn/attorneygeneral/documents/ops/2023/op23-09.pdf

Original opinion text

STATE OF TENNESSEE
OFFICE OF THE ATTORNEY GENERAL
July 27, 2023
Opinion No. 23-09

Authority of Elected Municipal Court Clerk to Set Bail

Question 1

When an elected municipal court clerk serves a municipal court that exercises concurrent jurisdiction with a general sessions court, does Tenn. Code Ann. § 40-11-105(a) or any other law authorize that clerk to set bail for a defendant who has been arrested or held to answer for any bailable offense? Specifically, is such a municipal court clerk the equivalent of a "clerk of any circuit or criminal court" under Tenn. Code Ann. § 40-11-105(a)?

Opinion 1

No. Neither Tenn Code Ann. § 40-11-105(a) nor any other general law authorizes an elected municipal court clerk to set bail, regardless of any concurrent jurisdiction that the municipal court may exercise with a general sessions court.

Question 2

If the answer to question 1 is "yes," are there any statutory limitations on the elected municipal court clerk's authority to set bail for a defendant who has been arrested or held to answer for any bailable offense?

Opinion 2

In light of Opinion 1, this question is moot.

Question 3

If the answer to question 1 is "yes," does the municipal court judge have the authority under state law to limit or revoke the authority of the elected municipal court clerk to set bail? If the municipal court judge does not have such authority under state law, can a city charter give the municipal court judge such authority?

Opinion 3

In light of Opinion 1, this question is moot.

Question 4

If the answer to question 1 is "yes," is there an authoritative governing body that can take corrective action against an elected municipal court clerk when the clerk violates his or her authority relative to setting bail amounts, and if so, which authoritative governing body can take such action?

Opinion 4

In light of Opinion 1, this question is moot.

ANALYSIS

Under Tennessee law, criminal defendants have a right to bail before trial except in capital cases. See Wallace v. State, 193 Tenn. 182, 185-86, 245 S.W.2d 192, 193 (1952) (citing Tenn. Const., art. I, § 15); Tenn. Code Ann. § 40-11-102. The statutory framework governing pretrial release and bail is predominately found in the "Release from Custody and Bail Reform Act of 1978" ("Bail Reform Act"). See Tenn. Code Ann. §§ 40-11-101, et seq.

Tennessee Code Annotated § 40-11-105(a) of the Bail Reform Act provides that a defendant is entitled to be "admitted to bail" when the defendant has been arrested or held to answer for any bailable offense. As currently codified, Tenn. Code Ann. § 40-11-105(a) authorizes only three categories of officials to admit defendants to bail—committing magistrates, judges of circuit and criminal courts, and clerks of circuit and criminal courts:

(a)(1) When the defendant has been arrested or held to answer for any bailable offense, the defendant is entitled to be admitted to bail by the committing magistrate, by any judge of the circuit or criminal court, or by the clerk of any circuit or criminal court; provided, that if admitted to bail by the clerk of any circuit or criminal court, the defendant has a right to petition the judge of the circuit or criminal court if the defendant feels that the bail set is excessive, and shall be given notice of this fact by the clerk.

(2) The clerk of any circuit or criminal court may only admit a defendant to bail when the judge is not present in the court and the clerk reasonably believes that the judge will not be present within three (3) hours after the defendant has been committed to the county or city jail, following arrest.

Tenn. Code Ann. § 40-11-105(a) (emphasis added).

As explained below, an elected municipal court clerk is not a "committing magistrate," a "judge of the circuit or criminal court," or a "clerk of any circuit or criminal court." Accordingly, Tenn. Code Ann. § 40-11-105(a) does not authorize an elected municipal court clerk to set bail for a defendant who has been arrested or held to answer for any bailable offense.

In construing statutes, a court's role is "to ascertain and give effect to the legislative intent without unduly restricting or expanding a statute's coverage beyond its intended scope." State v. Strode, 232 S.W.3d 1, 9 (Tenn. 2007). Thus, the first step in construing a statute is to "look at the . . . plain language." Spires v. Simpson, 539 S.W.3d 134, 143 (Tenn. 2017). The initial focus must be on the words of the statute, giving them their natural and ordinary meaning in light of their statutory context. Lee Med., Inc. v. Beecher, 312 S.W.3d 515, 526-27 (Tenn. 2010). If the language is clear and unambiguous, the task is at an end. See Keen v. State, 398 S.W.3d 594, 610 (Tenn. 2012). But if the language is ambiguous, the court may look to the broader statutory scheme, the legislative history, and other sources, including established canons of statutory construction. Spires, 539 S.W.3d at 144; State v. Marshall, 319 S.W.3d 558, 561 (Tenn. 2010); Colonial Pipeline Co. v. Morgan, 263 S.W.3d 827, 836 (Tenn. 2008).

Here, the plain language of the statute, read in the context of the Bail Reform Act, is clear: an elected municipal court clerk does not fall within any of the three categories of officials authorized to admit a defendant to bail under Tenn. Code Ann. § 40-11-105(a)—i.e., (1) judges of circuit and criminal courts, (2) clerks of circuit and criminal courts, and (3) magistrates.

First, an elected municipal court clerk is not a "judge of the circuit or criminal court." Judges are public officials who are authorized by law to hear and decide legal matters in court. 46 Am.Jur.2d Judges § 1 (2023); see In re Lawyers' Tax Cases, 55 Tenn. 565, 650 (1875). Clerks, on the other hand, are ministerial officers who serve as "arms" of the courts, subject to the direction, control, and supervision of the judge of the court. 15A Am.Jur.2d Clerks of Court § 1 (2023); see Bailey v. Schubert, 203 Tenn. 660, 666, 315 S.W.2d 249, 252 (1958).

Second, an elected municipal court clerk is not a "clerk of any circuit or criminal court," even when the clerk serves a municipal court that exercises concurrent jurisdiction with a general sessions court. An examination of the Bail Reform Act squarely substantiates that the phrase "clerk of any circuit or criminal court" is confined to those clerks who are elected pursuant to Tenn. Code Ann. § 18-4-101 to serve circuit and criminal courts, i.e., courts governed by Tenn. Code Ann. §§ 16-10-101, et seq. The phrase cannot be read to refer to any clerk that serves a court that has jurisdiction over criminal matters because the Bail Reform Act is replete with provisions that apply only to clerks of certain courts, while other provisions clearly encompass clerks of several courts. When "the legislature includes particular language in one section of a statute but omits it in another section of the same act, it is presumed that the legislature acted purposefully in including or excluding that particular subject." State v. Casper, 297 S.W.3d 676, 693 (Tenn. 2009); see Crowe v. Ferguson, 814 S.W.2d 721, 723 (Tenn. 1991).

For instance, some provisions of the Bail Reform Act apply generally to the "clerk of the court having jurisdiction of the offense," "the clerk of the court before which the proceeding is pending," "the clerk of the court," or simply "the clerk." In contrast, there are provisions like Tenn. Code Ann. § 40-11-105(a) that apply to specific clerks, such as Tenn. Code Ann. § 40-11-106(b)(1), which addresses the certification of surety by "the circuit court clerk." And particularly significant here, Tenn. Code Ann. § 40-11-107 and § 40-11-108 address the authority of "the city court clerk" to "take" bail.

These various provisions of the Bail Reform Act demonstrate that the phrase "clerk of any circuit or criminal court" in Tenn. Code Ann. § 40-11-105(a) does not include a municipal court clerk, especially in light of the Act's inclusion of "city court clerks" as officers authorized to "take" bail in § 40-11-107 and § 40-11-108 and the exclusion of those same clerks as officers authorized to admit a defendant to bail in § 40-11-105(a). Had the General Assembly intended Tenn. Code Ann. § 40-11-105(a) to include municipal court clerks, it would have specifically referred to these clerks in § 40-11-105(a) or it would have used language such as "the clerk of the court having jurisdiction of the offense" or "the clerk of the court before which the proceeding is pending," as it did in other sections of the Bail Reform Act. See Casper, 297 S.W.3d at 693; Crowe, 814 S.W.2d at 723. Accordingly, an elected municipal court clerk is not a "clerk of any circuit or criminal court." See Lind v. Beaman Dodge, Inc., 356 S.W.3d 889, 895 (Tenn. 2011).

Third, an elected municipal court clerk is not a committing "magistrate," a term which includes the following three groups of officials for the purposes of title 40: (a) "judges of the supreme, appellate, chancery, circuit, general sessions and juvenile courts throughout the state," (b) "judicial commissioners and county mayors in those officers' respective counties," and (c) "the presiding officer of any municipal or city court within the limit of their respective corporations." Tenn. Code Ann. § 40-1-106.

As explained earlier, clerks are not judges; thus, a municipal court clerk cannot be a "judge" of any of the courts permitted to admit a defendant to bail as a "magistrate."

An elected municipal court clerk is also obviously not a "county mayor" or a "judicial commissioner"—another county official. See Tenn. Code Ann. §§ 40-1-111; 40-5-201 to -204; Tenn. Att'y Gen. Op. 03-110 (Sept. 8, 2003).

Finally, an elected municipal court clerk is not "the presiding officer of any municipal or city court." Case law has only declared that "city court judges" are presiding officers of city courts and, therefore, "magistrates" under Tenn. Code Ann. § 40-1-106. State v. Ford, M2007-00431-CCA-R3-CD, 2008 WL 1968824, at *4-5 (Tenn. Ct. App. May 7, 2008); see Tenn. Att'y Gen. Op. 84-228 (July 24, 1984); Tenn. Att'y Gen. Op. 78-365 (Oct. 6, 1978). And while no court has considered whether any other official can be a presiding officer of a municipal court, legislative history for Tenn. Code Ann. § 40-1-106 appears to foreclose any assertion that a municipal court clerk could be a presiding officer of a municipal court. The caption of the 1973 Act that added the phrase "the presiding officer of any municipal or city court" to Tenn. Code Ann. § 40-1-106 states that it is "AN ACT to amend Section 40-114, Tennessee Code Annotated, to include judges of municipal courts within the definition of magistrates." 1973 Tenn. Pub. Acts, ch. 48 (emphasis added). And consistent with the caption of the Act, the bill was referred to as "the municipal city judge bill" during the House debates; no one suggested or otherwise indicated that municipal court clerks were also intended to become "magistrates" under the bill. See Womack v. Corrections Corp. of Am., 448 S.W.3d 362, 366 (Tenn. 2014).

In short, municipal court judges, not municipal court clerks, are "magistrates" authorized to admit defendants to bail under Tenn. Code Ann. § 40-11-105(a). And because admitting a defendant to bail is a discretionary task, it is a judicial function as opposed to a ministerial act. See State ex rel. Millers Nat'l Ins. Co. v. Fumbanks, 177 Tenn. 455, 462, 151 S.W.2d 148, 150-51 (1941). Thus, municipal court judges may not delegate the task of setting bail to municipal court clerks, i.e., ministerial officers. See 46 Am.Jur.2d Judges § 22 (2023); Tenn. Att'y Gen. Op. 99-008 (Jan. 25, 1999).

Accordingly, no provision of Tenn. Code Ann. § 40-11-105(a) authorizes elected municipal court clerks to set bail because elected municipal court clerks are not judges of circuit and criminal courts, clerks of circuit and criminal courts, or committing magistrates.

Furthermore, no other general law addressing the authority of municipal court clerks empowers such clerks to set bail. While Tenn. Code Ann. § 18-4-203 does authorize "the clerk of a general sessions court . . . to set the amount of bond in the absence the judge," this statute has no application to municipal court clerks, even when the municipal court clerk serves a municipal court that exercises concurrent jurisdiction with a general sessions court. Municipal courts that exercise concurrent jurisdiction with a general sessions court do so through Tenn. Code Ann. § 40-1-107, which provides: "Original jurisdiction of criminal actions is committed to . . . city judges of certain towns and cities . . . ." While this provision can allow a municipal judge, i.e., the municipal court, to exercise additional authority, see Tenn. Att'y Gen. Op. 08-136 (Aug. 15, 2008), this provision provides no additional authority to municipal court clerks.

When the General Assembly intends for a municipal court clerk to exercise the power of a general sessions court clerk, that intent is made clear. For instance, Tenn. Code Ann. § 6-54-303 describes how municipal court clerks are to issue execution on certain judgments and states that "the clerks shall assess the same fees and costs as allowable to clerks of general sessions court." Tennessee Code Annotated § 18-4-203, in contrast, does not contain this type of language.

In sum, neither Tenn Code Ann. § 40-11-105(a) nor any other general law authorizes an elected municipal court clerk to set bail, regardless of any concurrent jurisdiction that the municipal court may exercise with a general sessions court.

JONATHAN SKRMETTI
Attorney General and Reporter

ANDRÉE SOPHIA BLUMSTEIN
Solicitor General

LAURA T. KIDWELL
Assistant Solicitor General

Requested by:
The Honorable Esther Helton-Haynes
State Representative
425 Rep. John Lewis Way N.
Suite 502
Nashville, Tennessee 37243