Tennessee appeals court orders release of Covenant School shooter records, narrowing school-safety and copyright limits

A ruling that reshapes access to high-profile investigative files

A Tennessee Court of Appeals panel has ruled that key records tied to the March 27, 2023, Covenant School shooting in Nashville are subject to disclosure under the Tennessee Public Records Act, reversing a 2024 trial-court decision that had largely kept the materials from public release.

The decision addresses a years-long conflict among open-records requesters, the Metropolitan Government of Nashville and Davidson County and a group of parents connected to the school community who intervened to oppose broad disclosure. The dispute has centered on whether the shooter’s seized writings and related investigative materials must be made available for inspection once the criminal investigation is closed.

What the court said must happen next

The appellate ruling directs the trial court to revisit the record-by-record treatment of the materials rather than applying a blanket bar. The panel instructed that exemptions should be applied narrowly and that redactions, not wholesale withholding, should be used when only portions of a document qualify for protection.

The court also rejected the trial court’s reliance on federal copyright law as a basis to block public inspection of the writings. In earlier proceedings, families had asserted ownership interests in the shooter’s work as part of an effort to control access. The appeals court concluded that copyright does not operate as a categorical override of Tennessee’s public records requirements for the government’s investigative file.

• Records withheld solely on criminal-discovery grounds are to be released, the court said, in light of the case posture.
• The trial court must determine whether specific passages qualify for Tennessee’s school-safety exemption, applying a page-by-page review.
• Where an exemption applies to only part of a record, the court signaled redaction as the appropriate remedy.

Investigation status and why it mattered

A central factual and legal point in the appeal was the status of the police investigation. Metro Nashville Police Department publicly announced on April 2, 2025 that it had concluded its Covenant School mass murder investigation and released a 48-page report summarizing its work, clearing the case by exception because the shooter was killed at the scene and no prosecution could follow.

The appeals court treated the closed-investigation posture as significant to arguments that had previously been used to delay or narrow disclosure. While the ruling does not automatically require release of every line of every record, it establishes that the public-records analysis must proceed from the presumption of access, with exemptions justified with specificity.

What remains unresolved

The decision sends the case back to the trial court for expedited handling of the remaining exemption questions and for implementation of the court’s instructions on disclosure and redaction. The ruling also leaves open additional appellate steps; parties opposing release may seek further review within applicable deadlines.

If implemented as written, the ruling is likely to influence how Tennessee courts evaluate future requests involving school-violence investigative files, particularly when agencies and intervenors argue that release could create safety risks or when copyright claims are raised in public-records disputes.

The Covenant School shooting killed three 9-year-old students and three adult staff members. The shooter, a former student, was fatally shot by responding police officers.