Pauline Madron v. City of Morristown, Et AL.

This appeal concerns an alleged violation of the Open Meetings Act, Tenn. Code Ann. §
8-44-101, et seq. Pauline Madron (“Plaintiff”) sued the City of Morristown, Mayor Gary
Chesney, as well as Councilmembers Al A’Hearn, Chris Bivens, Robert Garrett, Tommy
Pedigo, Kay Senter, and Ken Smith (“Defendants,” collectively) in the Circuit Court for
Hamblen County (“the Trial Court”). Plaintiff alleged that the city’s public notice of a
July 12, 2019 special meeting to exceed the certified tax rate was inadequate. Plaintiff and
Defendants filed crossing motions for summary judgment. The Trial Court granted
Defendants’ motion for summary judgment with respect to Plaintiff’s Open Meetings Act
claim. Plaintiff appeals, arguing that the city’s notice that it intended to exceed the certified
tax rate was mere jargon that did not reasonably inform the public of the purpose of the
special meeting or the action to be taken. In response, Defendants argue that Plaintiff’s
Open Meetings Act claim is moot as it arises out of a property tax rate that was passed in
fiscal year 2019-2020, which lapsed before this matter was heard. Alternatively,
Defendants contend that, while most people may not understand the intricacies of city
finances, most people do understand what “exceed” and “tax rate” mean. While Plaintiff’s
claim is moot, it warrants resolution nevertheless. We hold that the city’s public notice of
the July 12, 2019 special meeting was adequate. We affirm.