Quinton Clovis v. Tennessee Human Rights Commissions
M2016-01534-COA-R3-CV
| Tenn. Ct. App. | Mar 21, 2017Background
- Quinton Clovis was ejected from the Metropolitan Public Library on Nov. 12, 2014 after security said he loudly described sexual exploits, used abusive language (including a slur), refused to comply with instructions, and would not leave; initial 30‑day suspension was escalated to one year after continued belligerence and police removal.
- Clovis claimed library staff targeted him because he was investigating local hate crimes and for his Christian beliefs (he said he read the Bible and listened to gospel music in the lab) and alleged staff attempted to seize/ destroy a flash drive and even poison his food.
- Library staff and supervisors denied prior knowledge of Clovis, denied knowledge of his religion, and described following library conduct policies in warning, suspending, and summoning police for a disruptive, abusive patron.
- Clovis filed a complaint with the Tennessee Human Rights Commission alleging denial of public accommodation on the basis of religion and retaliatory conduct; the Commission investigated and found no reasonable basis to proceed.
- Clovis appealed the Commission’s dismissal to Davidson County Chancery Court, which affirmed the Commission; Clovis appealed to the Court of Appeals, which affirmed the chancery court’s judgment.
Issues
| Issue | Clovis's Argument | Tennessee Human Rights Commission / Library Argument | Held |
|---|---|---|---|
| Whether the Library discriminated against Clovis on the basis of religion (denial of public accommodation) | Clovis: suspension was motivated by his Christian beliefs and related materials; staff targeted him and sought to destroy his flash drive | Library/Commission: suspension resulted from disruptive, abusive behavior; staff had no knowledge of his religion and followed published conduct rules | Held: No proof of religious discrimination; Commission’s dismissal affirmed |
| Whether the Commission’s factual finding should be disturbed on judicial review (standard of review) | Clovis: Commission erred in dismissing complaint | Commission/Chancery Court: findings are conclusive unless clearly erroneous; supported by probative and substantial evidence | Held: Commission’s factual findings supported by substantial evidence and are not clearly erroneous; dismissal affirmed |
Key Cases Cited
- Plasti-Line, Inc. v. Tenn. Human Rights Comm’n, 746 S.W.2d 691 (Tenn. 1988) (defines “probative and substantial evidence” standard for reviewing agency factual findings)
- Wayne Cnty. v. Tenn. Solid Waste Disposal Control Bd., 756 S.W.2d 274 (Tenn. Ct. App. 1988) (explains substantial and material evidence standard and that inferences and circumstantial evidence may support agency findings)