Jeff Preptit

• Zapata Dominguez v. Perez Ramirez, 3:24-cv-01154 (M.D. Tenn. 2025)

Zapata Dominguez v. Perez Ramirez, was a case filed in the Federal District Court for the Middle District of Tennessee under the Hague Convention on the Civil Aspects of International Child Abduction. The Hague Convention prohibits the wrongful removal of a child from their nation of habitual residence. In this case, the Petitioner alleged that his child was wrongfully removed from Mexico by her mother. After a length bench trial, we successfully defended the claims and the case was dismissed. 

• Jane Doe v. Jeff Long, et. al. (Chancery Court for Davidson County) (2024)

Doe v. Long is a case filed on behalf of a transgender woman to challenge TDSHS’ enforcement of a new rule that bans all transgender people from changing the gender marker on their driver licenses.  The plaintiff, “Jane Doe,” whose identity is being withheld out of concern for her safety, requested TDSHS update her driver license to reflect her correct gender and appearance. As a result of TDSHS’ enforcement of its new rule, which never passed through lawful procedures, Ms. Doe was denied an accurate license based on the mere fact that she is transgender.

• OUTMemphis, et. al. v. Lee, et. al., 2:23-cv-2670-SHL-CGC, (W.D. Tenn 2023).

OUTMemphis v. Lee is a first-of-its-kind challenge to a state-level HIV criminalization law as a violation of the Americans with Disabilities Act (ADA) and the Constitution. Plaintiffs OUTMemphis and Jane Does 1-4 seek to strike down Tennessee’s discriminatory, irrational and cruel enforcement of its “Aggravated Prostitution” law and related sex offender registration requirements. Tennessee criminalizes Prostitution as a misdemeanor. However, the state passed the Aggravated Prostitution statute in 1991, that only applies to people living with HIV who engage in sex work. Aggravated Prostitution is a felony and, starting in 1994 with the adoption of a Sex Offender Registry, those convicted of Aggravated Prostitution must register as a sex offender for ten years. In 2010, an Aggravated Prostitution conviction became classified as a “violent sexual offense” requiring lifetime registration as a sex offender. People on the sex offender registry for Aggravated Prostitution are there solely because of their HIV status. This is a clear violation of the Americans with Disabilities Act (ADA), which prohibits discrimination on the basis of a protected disability.

• Tennessee Equality Project Foundation, Inc., v. City of Murfreesboro et al., (M.D. Tenn 2023).

This suit was filed on behalf of the Tennessee Equality Project (TEP), founder and host of the annual BoroPride Festival. The lawsuit challenges a new anti-drag city ordinance and a local policy denying all special event request permits by TEP.

The lawsuit was filed after the Murfreesboro mayor and city manager engaged in a yearlong, concerted anti-LGBTQ+ campaign to chill TEP and Murfreesboro residents’ protected speech and expression, culminating in the city establishing an official policy prohibiting the issuance of permits to TEP; discriminatorily and unconstitutionally denying TEP’s request for a permit for 2023 BoroPride; and implementing a sweeping and vague ordinance designed to censor any LGBTQ+ speech or conduct within the Murfreesboro community or from TEP. This ordinance has already been utilized to ban multiple LGBTQ+ books from Murfreesboro public libraries.

• Polidor, et al., v. Sexton et al., (Chancery Court for Davidson County) (2023)

Polidor was a lawsuit on behalf of three Tennesseans who were forced to leave a Tennessee House subcommittee hearing by state troopers for quietly holding 8 ½ x 11 inch pieces of paper expressing their opinions on issues before the subcommittee. The plaintiffs were forced out under rules adopted by the Tennessee House of Representatives for the special session that ban signs in the galleries of the House of Representatives, denying the plaintiffs’ constitutional rights to speak freely, assemble and petition the government under the U.S. and Tennessee Constitutions. Ultimately the judge in the case blocked enforcement of a Tennessee House of Representatives rule for the special session that bans signs in the galleries of the House. 

• Blanchard et al. v. City of Memphis, 2:17-cv-02120-JPM-dkv, (W.D. Tenn 2017).

Blanchard v. City of Memphis, is a lawsuit challenging the City of Memphis’ creation of a list of people, including multiple members of the Black Lives Matter movement and other local political activists and organizers, who require a police escort while visiting City Hall. The existence of this so-called “blacklist” violates not only the First Amendment, but also a 1978 consent decree secured by ACLU-TN that banned the Memphis government from all future monitoring of constitutionally-protected political activities. The consent decree, the first in the nation of its kind, was the result of a multi-year investigation revealing a vast political surveillance network which the City of Memphis secretly operated for nearly a decade.