UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TENNESSEE
WINCHESTER DIVISION
I.P., a minor, by and through B.P., )
)
Plaintiff, )
)
v. ) Case No. 4:23-cv-00026
) Judge Katherine A. Crytzer
TULLAHOMA CITY SCHOOLS, a ) Magistrate Judge Susan K. Lee
political subdivision of the State of Tennessee; )
JASON QUICK, in his individual capacity; )
and DERRICK CRUTCHFIELD, in his )
individual capacity, )
)
Defendants. )
STIPULATION REGARDING PLAINTIFF’S MOTION FOR PRELIMINARY
INJUNCTION AGAINST DEFENDANT TULLAHOMA CITY SCHOOLS
Plaintiff I.P. and Defendant Tullahoma City Schools, through their counsel, hereby
stipulate and agree to the following:
1. On July 18, 2023, Plaintiff I.P. filed a Motion for Preliminary Injunction against Defendant
Tullahoma City Schools [Dkt. #4] seeking: (1) an injunction against the Tullahoma High
School Student Handbook rule against posting images or videos which “discredit,”
“embarrass,” or “humiliate” another student or member of staff [see Dkt. #5], (2) an
injunction against the Tullahoma High School Student Handbook rule against social media
posts “unbecoming of a Wildcat” [see id.], and (3) an order removing I.P.’s August 2022
suspension from his student record during the pendency of the litigation.
2. Following I.P.’s Motion, Tullahoma City Schools took voluntary, unilateral action to
remove the Tullahoma High School Student Handbook rule against posting images or
videos which “discredit,” “embarrass,” or “humiliate” another student or member of staff
from the Tullahoma High School Student Handbook.
1
Case 4:23-cv-00026-KAC-SKL Document 25 Filed 08/14/23 Page 1 of 4 PageID #: 144
3. Following I.P.’s Motion, Tullahoma City Schools took voluntary, unilateral action to
remove the Tullahoma High School Student Handbook rule against social media posts
“unbecoming of a Wildcat” from the Tullahoma High School Student Handbook.
4. For purposes of I.P.’s Motion for Preliminary Injunction, and without admission of error
or wrongdoing, Tullahoma City Schools agrees to make a correction to I.P.’s student
record, to remove I.P.’s 3-day out of school suspension that was assessed 8/10/22.
Tullahoma City Schools confirms that, following the correction to I.P.'s records, there
exists no August 2022 suspension on I.P.’s school record. I.P. and Tullahoma City Schools
agree this shall not be deemed an admission of error in the original disciplinary assessment,
and shall not be weighed into any prevailing party analysis unless and until this matter is
resolved by settlement, dispositive motion, or a final trial on the merits.
5. Tullahoma City Schools agrees that, no later than 5:00 p.m. eastern on 8/14/23, it will send
I.P.’s counsel a sworn statement verifying that Tullahoma City Schools has corrected I.P.’s
student record and removed I.P.’s 8/10/22 3-day out of school suspension.
6. I.P. agrees that, within 24 hours of receiving the sworn statement referenced in Paragraph
5, I.P.’s counsel will file a notice with the Court withdrawing I.P.’s Motion for Preliminary
Injunction without prejudice to refile.
Respectfully submitted this 14th day of August, 2023.
/s/ Conor T. Fitzpatrick
Conor T. Fitzpatrick (Mich. Bar #P78981)
Harrison M. Rosenthal (PA Bar #332452)
Foundation for Individual Rights and
Expression
510 Walnut St., Ste. 1250
Philadelphia, PA 19106
Telephone: 215-717-3473
Conor.fitzpatrick@thefire.org
Harrison.rosenthal@thefire.org
2
Case 4:23-cv-00026-KAC-SKL Document 25 Filed 08/14/23 Page 2 of 4 PageID #: 145
Darrick L. O’Dell (#026883)
Spicer Rudstrom, PLLC
414 Union St., Ste. 1700
Nashville, TN 37219
Telephone: 615-259-9080
dlo@spicerfirm.com
Attorneys for Plaintiff
/s/ Jerome D. Pinn
Kenneth S. Williams (#010678)
Jerome D. Pinn (#017848)
Wimberly Lawson
Wright Daves & Jones, PLLC
P.O. Box 655
1420 Neal Street, Suite 201
Cookeville, TN 38503-0655
Telephone: (931) 372-9123
kwilliams@wimberlylawson.com
Attorney for Defendant TCS
3
Case 4:23-cv-00026-KAC-SKL Document 25 Filed 08/14/23 Page 3 of 4 PageID #: 146
CERTIFICATE OF SERVICE
I hereby certify that on August 14, 2023, I electronically filed the foregoing document with
the Clerk of the Court using the ECF system which will send notification of such filing upon all
ECF filing participants.
/s/ Conor T. Fitzpatrick
Conor T. Fitzpatrick
FOUNDATION FOR INDIVIDUAL
RIGHTS AND EXPRESSION
Case 4:23-cv-00026-KAC-SKL Document 25 Filed 08/14/23 Page 4 of 4 PageID #: 147
