To Mayor Indya Kincannon, the Knoxville City Council, CC: Mayor Glenn Jacobs, the Knox County Commission, City Recorder:

On behalf of the African-American people in Knoxville Tennessee, I am calling on the City Administration and the City Council to take immediate action to correct multiple legislative failures and a significant Constitutional Violation regarding the Jacob Building. This notice serves as a formal challenge to the City’s non-compliance with the Knoxville City Charter and its fiduciary duty to the public. On August 19, 2025, an 8-1 vote authorized a 20-year lease of a 57,000-square-foot public asset for $1.00 a year—a decision that bypasses the Charter’s intent for the equitable management of city property and ignores the standing legislative mandate of Resolution R-367-2020.

The Muse Knoxville has announced plans to begin construction/renovation in 2027, with a projected grand opening in Summer 2028. At the time of the August 2025 vote, the City was already 4 years and 8 months behind on the mandate established by Resolution R-367-2020, which requested the Administration to identify $100 Million in grant opportunities over a ten-year period to support strategic solutions for the African-American community. As of today, that timeline has reached 5 years and 3 months.

This lease is a continuation of the systemic disinvestment that has characterized the East Side for decades. When Urban Renewal destroyed the businesses and economic ecosystems of the Bottom, Morningside, and Mountain View, African-American residents were forced into Burlington, the Magnolia Corridor, and Five Points. Today, the City continues to deny these residents the opportunity for generational wealth by leasing away the Jacob Building—a central asset in the heart of these disinvested neighborhoods—for a nominal fee and no genuine economic benefit to the African-American people.

Furthermore, the 2025 University of Tennessee study, "Who is Using Knoxville’s Urban Wilderness?", found that 95% of the users of Knoxville’s major park and trail systems are non-black residents. This statistic is a direct result of decades of systemic exclusion. By choosing to lease 100% of this space to a single private entity without an equitable shared-use model, the City is doubling down on a system that intentionally excludes the local population from its own public assets.

Failure of the Restoration Mandate Under Resolution R-367-2020, the City Council requested the Administration identify $100 Million in funding. However, the African-American Equity Restoration Task Force has failed to identify a single victim or descendant of urban renewal for restitution. By giving away the Jacob Building for $1.00 instead of utilizing it for an African-American Incubator for Economic Investment and Development, the City is actively obstructing the very restoration it legislatively promised.

Violations of the Tennessee Open Meetings Act (TOMA) The City’s reliance on "6,300 visitor surveys" to bypass a formal public hearing is a direct violation of the following sections of the Tennessee Code Annotated (T.C.A.):

• T.C.A. § 8-44-101: Violation of the public policy that decisions be conducted openly.

• T.C.A. § 8-44-103: Violation of the requirement for adequate public notice.

• T.C.A. § 8-44-112: Violation of the mandate for a public comment period germane to the specific actionable item: The 20-year Lease Agreement for the Jacob Building.

Under T.C.A. § 8-44-105, any action taken in violation of this part is void and of no effect. This provides the current City Council the legal mechanism to acknowledge these violations and bring this matter into compliance with the law.

Constitutional Violation: The Illegal Gift (Art. II, § 29) Leasing a multi-million dollar public asset for $1.00 while a massive legislative debt to the African-American community remains unpaid is a violation of Article II, Section 29 of the Tennessee Constitution. At current market rates of $30 per square foot, the City is surrendering $1.71 Million in annual rental income, totaling $34.2 Million over the lease term. This "gift" cannot be justified while the City remains delinquent on its restoration mandate.

Demand for Shared-Use and Legislative Correction This is an opportunity for the Council to correct these violations and end the cycle of disinvestment. On behalf of the African-American people in Knoxville, Tennessee, I am demanding a Shared-Space Model for the Jacob Building:

This notice serves as a formal record of non-compliance regarding the Jacob Building and Chilhowee Park. I am demanding a full forensic audit of the asset valuation and a stay on all lease proceedings until the Constitutional and Charter violations are addressed.

Furthermore, I demand that the 2026 Parks & Recreation Master Plan (approved March 17, 2026) and the Chilhowee Park Advisory Group (meeting March 24, 2026) formally incorporate a Legally Binding Equity Restoration Framework. This framework must fulfill the $100 million commitment established in Resolution R-367-2020 to ensure that the African American people in the City of Knoxville receive documented, direct economic benefit and generational wealth-building opportunities from these public assets.

The City’s discretion ends where the Tennessee Constitution and its own legislative mandates begin. I demand immediate accountability and a correction of these violations of Tenn. Const. Art. II § 29 and T.C.A. §§ 8-44-101, 103, 105, and 112.