A Tennessee woman accused in court of “disrupting the government” by filing numerous records requests has pushed back, saying the lawsuit was “filed by a thin-skinned city government against a concerned citizen for asking too many questions.”
Sarah Bradley, a resident and former teacher in Manchester, Tennessee, has filed a counter First Amendment lawsuit on Aug. 13 after the city filed for an injunction against her in July. Her countersuit asks the court to require the city to answer her filings in trial, and to award her damages and costs.
The city’s injunction seeks to ban Bradley from making records requests for one year, as well as asking for explanations of records, and would require her to ask a court for permission before filing further
requests, after she filed multiple public records requests regarding the city’s sewer system over the past three years.
The city stated that she filed "six or more" requests for public documents within the past 12 months, in addition to records requests filed since late 2023, and claimed these requests were intentionally disruptive.
The city’s filing stems from a 2021 law that allows a court to ban a person from making additional records requests for up to one year if there’s evidence that the requests were made “with the intent to disrupt government operations.”
Bradley’s counter-filing said her actions are in no way disruptive, and calls the city's complaints “both trivial and a basic governmental responsibility.”
“Over three years, 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,” the court documents state. “Bradley asked about unpermitted fill sites, sanitary sewer overflows into the Little Duck River, Bonnaroo dumping, Land Use Subcommittee meetings, and where the City’s money goes.”
Daniel Horwitz, a First Amendment attorney representing Bradley, called the city's allegations “outrageous.”
“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,” he said. “The City of Manchester for some reason wanted this fight, and they are going to get it good and hard.”
Bradley’s filings address some of the allegations in the city’s July documents, acknowledging that she filed multiple records requests — some lengthy in nature — but said they were not filed with the intent to disrupt the government.
For instance, she filed a November 2023 request that had 26 parts, and a Nov. 17, 2025 request with 50 parts.
According to the filing, the City’s largest single documented cost — over three years, spread across multiple city departments — “was just fifteen staff hours, 182 copies, and $483.81.”
“Requesting public records, standing alone, does not constitute disruptive conduct,” her filing states, later adding that some of the records led to her reporting her findings to federal and state regulators.
According to local reporting by Thunder Radio, the city was fined $146,000 in February after the Tennessee Department of Environment and Conservation issued an order stating that Manchester had108 sanitary sewer overflow events between January 2025 and December 2025. These events resulted in more than 25,000,000 gallons of overflow.
“Bradley’s public-records requests, her communications with City officials about those records, and her reports to regulators are all speech and petitioning behavior protected by the First Amendment,” her filings state.
The Tennessean has reached out for updated comments from Manchester City Mayor Joey Hobbs regarding the new filings.
In a recent conversation with The Tennessean, Hobbs said the City of Manchester is "committed to transparent government and the right for citizens to have access to records," but called Bradley's requests "voluminous and unclear."
"We believe that Ms. Bradley has abused the law and intentionally used the law to disrupt operations at the city by filing an exhaustive amount of record requests that number in the hundreds," he stated, adding that "Despite responding to every request with what we have to provide, she is never satisfied and bombards our Records Custodian's office with berating and accusatory emails and other communications that disrupt our other operations."
Bradley disputed the city’s accusations of “disruptive and aggressive behavior.”
“Arguing with the government, questioning government officials, asking the government to explain itself, and pressing the government on how it conducts the public’s business are not acts of misconduct to be enjoined: They are the core of what the First Amendment protects,” her filing states. “A citizen does not forfeit First Amendment rights by using them frequently or by asking too many questions of government officials who would rather not engage citizens or be held to account.”
It further says:
“In short, Bradley did exactly what a concerned, engaged citizen would do and what the Public Records Act exists to allow citizens to do: She watched her government, and she acted on what she found,” the filing states. “The city does not like being watched. Thus, upset with Bradley’s scrutiny of its conduct, it has sued her.”
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This article originally appeared on Nashville Tennessean: Woman accused of disruption for too many records requests pushes back
