Daniel Renteria-Villegas v. Metropolitan Government of Nashville and Davidson County
2012 Tenn. LEXIS 734
| Tenn. | 2012Background
- MOA (Oct. 2009) between ICE and Nashville-Davidson County Sheriff’s Office (DCSO) authorized select DCSO personnel to perform certain ICE immigration officer duties after training and certification.
- MOA procedures include interrogations about status, processing removable aliens, detainers, and coordinating with ICE supervisors
- Metro directed the Sheriff to perform immigration functions per the MOA and resolved to cooperate with federal authorities
- Charter of Nashville and Davidson County assigns Police Chief as principal conservator of the peace and reserves custody of the metropolitan jail to the Sheriff; the Sheriff’s duties are set by Charter 16.05 and by general law
- Poe (1964) held that the Sheriff’s authority to preserve the public peace was transferred to the Police Chief, but the ruling is read as narrow to removing the Sheriff’s role as principal conservator; MOA is challenged on grounds of Charter or state law
- Court concludes the MOA does not violate the Charter or state law and is authorized by Charter §18.17 permitting cooperation with federal programs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the MOA violate the Charter or state law? | Renteria argues MOA infringes Charter’s conservator of peace allocation | Metro and Sheriff argue MOA falls within cooperative power and Charter §18.17 | No violation; MOA authorized by Charter and state law |
| Does Poe bar Sheriff immigration duties under MOA? | Poe divests Sheriff of public peace duties | Poe’s scope is limited; MOA not prohibited | Poe does not prohibit Sheriff performing MOA duties when directed by Metro |
| Is the MOA compatible with Tenn. Code Ann. §50-1-101(a)/(b)? | Section 50-1-101(b) designates local officers for MOUs | Charter does not prohibit Sheriff from such functions; MOA valid | MOA valid under statute; Sheriff authorized to execute agreement on Metro’s behalf |
Key Cases Cited
- Seals v. H & F, Inc., 301 S.W.3d 237 (Tenn. 2010) (rule for certified questions and interpretation of Charter)
- Haley v. Univ. of Tenn.-Knoxville, 188 S.W.3d 518 (Tenn. 2006) (promotes judicial efficiency in interpreting state law)
- Poe v. Metro Gov't of Nashville & Davidson Cnty., 383 S.W.2d 265 (Tenn. 1964) (discusses division of law-enforcement duties between Sheriff and Police Chief)
- Jordan v. Knox Cnty., 213 S.W.3d 751 (Tenn. 2007) (statutory construction principles for Charter interpretation)
- Colonial Pipeline Co. v. Morgan, 263 S.W.3d 827 (Tenn. 2008) (uses broader statutory context when language is ambiguous)
- Waldschmidt v. Reassure Am. Life Ins. Co., 271 S.W.3d 173 (Tenn. 2008) (requires enforcing Charter language as written when clear)