The Tennessee Supreme Court recently issued a significant ruling regarding the Metropolitan Government of Nashville and Davidson County's challenge to a state law capping the size of metropolitan councils. The court's decision affects local governance and constitutional law in Tennessee, particularly regarding the balance of power between state and local authorities.

The case, Metropolitan Government of Nashville and Davidson County v. Bill Lee, Governor, was filed under docket number M2024-01182-SC-R11-CV. It centers on a law passed by the Tennessee General Assembly in 2023, which imposed a cap of twenty members on metropolitan councils. This ruling not only impacts Nashville but also sets a precedent for how local governments can operate within the framework of state law.

Background

The dispute began when the Tennessee General Assembly enacted House Bill No. 48 (H.B. 48) in March 2023, which limited the size of metropolitan councils to twenty members. This legislation was met with immediate backlash from the Metropolitan Government of Nashville and Davidson County, which argued that the cap violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. The plaintiffs claimed that the law undermined their local governance structure, which had been established through a charter allowing for a larger council.

The case progressed through the court system, with the trial court initially siding with Nashville, stating that the cap violated the aforementioned constitutional clauses. However, the Court of Appeals later reversed this decision, prompting Nashville to appeal to the Tennessee Supreme Court. The Supreme Court's review was further complicated by subsequent amendments to the law that were passed while the case was pending.

The Ruling

The Tennessee Supreme Court, led by Justice Sarah K. Campbell, ruled on November 2, 2026. The court decided that the amendments made to H.B. 48 rendered the plaintiffs' Local Legislation Clause claim moot, as the revisions eliminated the problematic language that had initially linked the cap to specific enforcement provisions. The court stated, "We conclude that those amendments render the plaintiffs’ Local Legislation Clause claim moot, and we therefore vacate the judgment of the Court of Appeals with respect to that issue."

However, the court did not find the Exemption Clause claim to be moot. The court affirmed the Court of Appeals' decision regarding this claim, stating that the cap did not violate the Exemption Clause. The ruling emphasized that the Exemption Clause does not prevent the legislature from imposing limits on metropolitan councils, thereby allowing the cap to stand. The court noted, "We agree with the Court of Appeals that the cap does not violate the Exemption Clause."

Impact

This ruling has significant implications for local governance in Tennessee. By upholding the cap on metropolitan councils, the Tennessee Supreme Court has reinforced the authority of the state legislature over local governments. This decision may serve as a precedent for future legislative actions that seek to limit or redefine the powers of local governing bodies across the state.

The ruling also highlights the ongoing tension between state and local authorities, particularly in how local governments can operate independently. As Nashville adjusts to the new council size, other metropolitan areas in Tennessee may also need to consider how this ruling affects their governance structures and legislative capabilities.

What's Next

While the Tennessee Supreme Court's decision is final regarding the current claims, it is possible that Nashville or other local governments may seek further legislative changes or pursue new legal challenges in the future. The court's ruling does not preclude additional lawsuits that may arise from the ongoing evolution of local governance laws in Tennessee.