Amanda Collins

8732 Hollingsfield Drive

Knoxville, TN 37922
(865) 951-1161 (landline)
knoxcollins5@gmail.com

16th February 2022

Ethics Committee, Board of Education

Knox County Schools
912 South Gay Street
Knoxville, Tennessee 37902
(865) 594-1800
Mike McMillan, District 8
michael.mcmillan1@knoxschools.org
Jennifer Owen, District 2
jennifer.owen@knoxschools.org
Evetty Satterfield, District 1
evetty.satterfield@knoxschools.org

Dear Mr. McMillan, Ms. Owen, and Ms. Satterfield:

I am a Knox County District 4 resident and parent of three students in Knox County Schools. I am writing to file two
formal ethics complaints against Board members Betsy HENDERSON, Susan HORN, and (Board Chair) Kristi
KRISTY, for the facts described below.

Please consider this my formal request that the Ethics Committee investigate the facts and make recommendations
for next actions in accordance with Knox County Board of Education Policy B-220, Code of Ethics1.

Complaint 1:
Regarding Knox County Board of Education Policy, B-112, Duties of Board Members: Duty 6. To accept the will of
the majority vote in all cases and give support to the resulting action (B-112:6)2:

1. February 9, 2022: In the Board of Education Regular Session, the Board passed five different motions
regarding the Knox County Law Department’s involvement in litigating the preliminary injunction issued by
U.S. District Judge J. Ronnie Greer requiring universal masking in Knox County Schools pending the
outcome of the lawsuit or a change in orders. All five motions passed with 5-4 votes3 and empowered the
Law Department “to do everything they feel is possible as quickly as they can that does not violate rules or
jeopardize the case.” (See meeting minutes of February 9, 2022, when available.)

2. February 9, 2022: HENDERSON and KRISTY submitted a signed letter to Knox County Law Director David
Buuck (attached) that stated:

“We are formally requesting that [Buuck] immediately hire expert outside counsel to represent the
Knox County Board of Education in the Case 3:21-cv-00317-JRG-DCP, known as the mask mandate

www.knoxschools.org/cms/lib/TN01917079/Centricity/Domain/974/board%20policies/B-220%20Code%20of%20E
thics.pdf
2

www.knoxschools.org/cms/lib/TN01917079/Centricity/Domain/974/board%20policies/B-112%20Duties%20of%20
Board%20Members.pdf
3
Mayshark, J. F. (February 10, 2022). Finalists and frustrations: The school board names three superintendent
candidates, while searching for a way out of its court-ordered mask mandate.
https://compassknox.com/2022/02/10/finalists-and-frustrations/. Retrieved February 16, 2022.
case….As members of the Board of Education, if you refuse to hire outside counsel, we are
requesting that the Knox County Commission pass a resolution for the Board to do so.”

3. February 14, 2022: Mr. Buuck responded by letter (attached) to HENDERSON and KRISTY:

“You have also been made aware of the law in this county as set out by Chancellor Sharon Bell in
2003, wherein she held that the school board could not hire outside counsel. Even if possible, the
hiring of outside counsel would cause significant additional expense and would only replicate that
which our Office has already filed….As a final note, although you are free to express your
individual opinions on the campaign trail and otherwise, you have no authority to represent the
KCSBOE outside of what the full Board has approved. I point out what you request is contrary to
the Motion passed at the February 9, 2022 meeting that “the Law Department do everything they
feel is possible as quickly as they can that does not violate rules or jeopardize the case. This
Office is following that direction of the Board and will continue to do so.”

4. February 15, 2022: HENDERSON, KRISTY, and HORN attended the Knox County Commission Work Session
and presented a resolution to the Commission to authorize the Board to hire outside counsel4. (See
meeting minutes of February 15, 2022, when available.)

The February 9 letter from HENDERSON and KRISTY, on behalf of the full Board without authorization, requesting
that Mr. Buuck hire outside counsel–despite the Board’s approved motion of February 9–violated B-112:6.

The February 15 appearance of HENDERSON, HORN, and KRISTY at Commission to request a resolution
authorizing the Board to hire outside counsel, on behalf of the full Board without authorization–despite both the
Board’s approved motion of February 9 and Mr. Buuck’s written response of February 14–violated B-112:6.

Complaint 2:
Regarding T.C.A. § 8-44-103 Tennessee Open Meetings Act (b) Notice of Special Meetings. Any such governmental
body which holds a meeting not previously scheduled by statute, ordinance, or resolution, or for which notice is not
already provided by law, shall give adequate public notice of such meeting:

1. When HENDERSON, HORN, and KRISTY met at the February 15 County Commission meeting and jointly
requested, on behalf of the full Board yet without authorization, a resolution from Commission to authorize
the Board to hire outside counsel, they violated Tennessee state code regarding Notice of Special
Meetings by failing to provide adequate public notice of their attendance.

2. Additionally, HENDERSON, HORN, and KRISTY were accompanied at the Commission meeting by
approximately 30 supporters, suggesting that not only did the these Board members privately
communicate to arrange this appearance–by electronic or other means–but that they also selectively
disseminated their intent to appear, thus failing to provide adequate public notice of such meeting.

By privately communicating to decide and arrange the actions of February 15 and selectively disseminating their
intent to appear at Commission, HENDERSON, HORN, and KRISTY violated the Tennessee Open Meetings Act.

Please respond to my complaints and initiate an investigation into Board members HENDERSON, HORN, and
KRISTY at the earliest opportunity.

Thank you for your time and prompt attention,

Amanda Collins

cc: Gary Dupler, Terri Coatney

4
Mayshark, J. F. (February 16, 2022). Legal Maneuvers: Three school board members ask County Commission
for authority to hire their own attorney in the school mask lawsuit.
https://compassknox.com/2022/02/16/legal-maneuvers/. Retrieved February 16, 2022.