# Memphis *City in Shelby County, Tennessee, United States; named in a May 2025 Department of Justice batch retraction that included the Minneapolis findings.* Memphis is the county seat of Shelby County, Tennessee, and lies on the [[Mississippi River]]. The 2020 census counted 633,104 residents, the second-largest city population in the state.[^1] Memphis is in the Minnesota record because of one federal action. On May 21, 2025, the U.S. Department of Justice Civil Rights Division announced in release 25-534 that it was moving to "dismiss with prejudice" its suits concerning [[Minneapolis]] and [[Louisville]]. In the same release it retracted the findings in those investigations and the findings as to [[Phoenix]], [[Trenton]], Memphis, [[Mount Vernon]], [[Oklahoma City]] and the [[Louisiana State Police]].[^2] The project's at-issue item records that Minneapolis was retracted as one of a batch and was not singled out.[^2] Two U.S. Supreme Court decisions with "Memphis" in their captions also appear among the project's claim:link pairs. *Memphis Light, Gas and Water Division v. Craft* (1978) concerns process before a public utility terminates service.[^3] *Memphis Community School District v. Stachura* (1986) concerns damages for the deprivation of rights.[^4] ## Where The city sits on a bluff above the Mississippi. Its metropolitan area reaches into southwest Tennessee, northern Mississippi and eastern Arkansas, and Interstates 40 and 55 enter the city across the river from Arkansas.[^1] The [[United States Census Bureau]] measures the city at 324.0 square miles: 315.1 square miles of land and 9.0 square miles (2.76%) of water.[^1] The riverfront runs from Meeman-Shelby Forest State Park at its northern end to T. O. Fuller State Park at its southern end.[^1] The city's boundaries have recently contracted. Under a three-phase plan covering five areas, the first phase took effect on January 1, 2020, when the Eads and River Bottoms areas were returned to unincorporated Shelby County. That phase cut the city's area by 5% and its population by 0.03%, and policing of those areas passed to the Shelby County [[sheriff]].[^1] ## When - **1541**: European exploration of the site began with Hernando de Soto.[^1] - **1819**: John Overton, James Winchester and Andrew Jackson founded the modern city.[^1] - **1963**: The city adopted a mayor-council government with 13 council seats, six at-large and seven by district.[^1] - **April 4, 1968**: Martin Luther King Jr. was assassinated in Memphis.[^5] - **1995**: After court challenges to at-large voting under the Voting Rights Act of 1965, the city adopted a council plan of nine districts. Seven are single-member districts and two elect three members each.[^1] - **January 1, 2020**: The first phase of deannexation took effect.[^1] - **January 1, 2024**: Paul Young, a Democrat, took office as mayor.[^1] - **May 21, 2025**: The Department of Justice retracted the Memphis findings in the batch action described below.[^2] ## In the at-issue record **The batch retraction.** Release 25-534 of May 21, 2025 joined two steps in one action: - It moved to dismiss the Minneapolis and Louisville suits with prejudice and closed both investigations. - It retracted the findings as to those two jurisdictions and six others, including Memphis.[^2] The release, quoting Assistant Attorney General Dhillon, describes the action as "ending the Biden Civil Rights Division's failed experiment of handcuffing local leaders."[^2] The two sources count the jurisdictions differently. At-issue item 031 says the Department retracted "six others" besides Minneapolis but lists seven names, counting Louisville. The release, as recorded in the dossier note, places Louisville with Minneapolis among the dismissed suits and names six further jurisdictions.[^2] The pack does not contain the Memphis findings or their date, so this record does not establish what they found. **What the same action ended in Minneapolis.** The Minneapolis instrument retracted alongside Memphis has a documented sequence: - **April 21, 2021**: DOJ opened a pattern-or-practice investigation of the [[City of Minneapolis]] and the [[Minneapolis Police Department]] under 34 U.S.C. § 12601. The investigation was announced one day after the [[Chauvin verdict]].[^6] - **June 16, 2023**: In release 23-674, the Department found reasonable cause that MPD "uses excessive force, including unjustified deadly force and unreasonable use of tasers." It also found that MPD "unlawfully discriminates against Black people and Native American people in its enforcement activities."[^7] The full findings report runs 89 pages.[^8] - **January 6, 2025**: A 169-page [[consent decree]] providing for an independent monitor was filed in [[United States v. City of Minneapolis (MPD consent decree)]], No. 0:25-cv-00048 (D. Minn.).[^9] - **May 21, 2025**: The Department moved to dismiss that case and retracted the findings in the batch action.[^2] Judge [[Paul A. Magnuson]] then granted dismissal with prejudice. He denied the settlement-approval motion as moot and cited "grave misgivings about the proposed consent decree serving the public interest."[^10] The sources disagree on the date of the order. Sahan Journal reports May 28, 2025, while the Clearinghouse docket dates the dismissal May 27, 2025; the dossier carries the discrepancy without resolving it.[^10][^6] **The state instrument the batch did not reach.** The Minnesota Department of Human Rights pursued its own case against Minneapolis: - **June 1, 2020**: MDHR filed a charge. - **April 27, 2022**: It found probable cause of a pattern or practice of race discrimination in violation of the [[Minnesota Human Rights Act]].[^11] - **March 31, 2023**: A court-enforceable settlement was filed in *Minnesota v. Minneapolis Police Department*, [[No. 27-CV-23-4177]].[^12] - **July 13, 2023**: Judge Karen Janisch of [[Hennepin County District Court]] approved the settlement. It ends only on a finding of "full, effective, and sustained compliance."[^12][^13] - **March 18, 2024**: The [[independent evaluator]], ELEFA, began work.[^14] See also [[At issue 031 - When DOJ retracted the Minneapolis findings it retracted]]. ## In the Minnesota record ### What The project's claim:link pairs cite three entries involving Memphis-captioned Supreme Court decisions: - ***Memphis Light, Gas and Water Division v. Craft*, 436 U.S. 1 (1978).** It is cited for procedural-due-process protection when public-utility service is terminated. It appears under Theory 10 (APA / constitutional avoidance) and Theory 12 (procedural due process, pre-termination process).[^3] - ***Memphis Community School District v. Stachura*, 477 U.S. 299 (1986).** It is cited under Theory 12 for the rule that the abstract value of a right is not recoverable and actual injury is required.[^4] The pack does not state where the Stachura school district is located. ## Notes [^1]: Wikipedia contributors, *Memphis, Tennessee* (revision 1382036917, retrieved 2026-10-27) — county seat, river location, 2020 census population, area, riverfront, deannexation, founding, government history and current mayor. https://en.wikipedia.org/wiki/Memphis,_Tennessee [^2]: U.S. Department of Justice, Civil Rights Division, *Release 25-534* (May 21, 2025) — motion to dismiss the Minneapolis and Louisville suits with prejudice; retraction of findings including those as to Memphis; AAG Dhillon statement. https://www.justice.gov/opa/pr/us-department-justices-civil-rights-division-dismisses-biden-era-police-investigations-and [^3]: Supreme Court of the United States, *Memphis Light, Gas and Water Division v. Craft*, 436 U.S. 1 (1978) — procedural-due-process protection for termination of public-utility service. https://supreme.justia.com/cases/federal/us/436/1/ [^4]: Supreme Court of the United States, *Memphis Community School District v. Stachura*, 477 U.S. 299 (1986) — abstract value of rights not recoverable; actual injury required. https://supreme.justia.com/cases/federal/us/477/299/ [^5]: Wikipedia contributors, *Assassination of Martin Luther King Jr.* (Time Table row TL-0203) — King assassinated in Memphis on April 4, 1968. https://en.wikipedia.org/wiki/Assassination_of_Martin_Luther_King_Jr [^6]: Civil Rights Litigation Clearinghouse, *United States v. City of Minneapolis* docket, case 18178 — investigation opened April 21, 2021 under 34 U.S.C. § 12601; dismissal dated May 27, 2025. https://clearinghouse.net/case/18178/ [^7]: U.S. Department of Justice, Civil Rights Division, *Release 23-674* (June 16, 2023) — reasonable-cause findings as to MPD and the City of Minneapolis. https://www.justice.gov/archives/opa/pr/justice-department-finds-civil-rights-violations-minneapolis-police-department-and-city [^8]: U.S. Department of Justice, Civil Rights Division, *Investigation of the City of Minneapolis and the Minneapolis Police Department* (June 2023) — the 89-page findings report. https://www.justice.gov/d9/2023-06/minneapolis_findings_report.pdf [^9]: U.S. Department of Justice, *Release on the Minneapolis consent decree* (January 2025) — consent decree filed January 6, 2025, No. 0:25-cv-00048 (D. Minn.), 169 pages, independent monitor. https://www.justice.gov/archives/opa/pr/justice-department-reaches-agreement-city-minneapolis-and-minneapolis-police-department [^10]: Sahan Journal, *Minneapolis federal consent decree dismissed* (May 2025) — Judge Magnuson's order of May 28, 2025 and the quoted passage. https://sahanjournal.com/public-safety/minneapolis-federal-consent-decree-dismissed/ [^11]: Minnesota Department of Human Rights, *Investigation into the City of Minneapolis and the Minneapolis Police Department* (April 27, 2022) — charge of June 1, 2020; probable-cause finding under the Minnesota Human Rights Act. https://mn.gov/mdhr/assets/Investigation%20into%20the%20City%20of%20Minneapolis%20and%20the%20Minneapolis%20Police%20Department_tcm1061-526417.pdf [^12]: Minnesota Department of Human Rights, *Civil rights update on the MPD settlement* (2023) — settlement filed March 31, 2023 and approved July 13, 2023, No. 27-CV-23-4177; termination standard. https://mn.gov/mdhr/news-community/newsroom/civilrightsupdates.jsp?id=1061-584578 [^13]: Minnesota Department of Human Rights, *MPD court-enforceable agreement* (document hub) — settlement documents. https://mn.gov/mdhr/mpd/agreement/ [^14]: Civil Rights Litigation Clearinghouse, *Minnesota v. Minneapolis Police Department* docket, case 43326 — No. 27-CV-23-4177; independent evaluator ELEFA began March 18, 2024. https://clearinghouse.net/case/43326/