City of Gallatin v. Gallatin Data Centers, LLC; Gallatin Data Centers, LLC and Phoenix Data Center Holdings, LLC v. City of Gallatin and Gallatin Department of Electricity

CourtDistrict Court, M.D. Tennessee
DecidedMarch 24, 2026
Docket3:24-cv-00868
StatusUnknown

This text of City of Gallatin v. Gallatin Data Centers, LLC; Gallatin Data Centers, LLC and Phoenix Data Center Holdings, LLC v. City of Gallatin and Gallatin Department of Electricity (City of Gallatin v. Gallatin Data Centers, LLC; Gallatin Data Centers, LLC and Phoenix Data Center Holdings, LLC v. City of Gallatin and Gallatin Department of Electricity) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Gallatin v. Gallatin Data Centers, LLC; Gallatin Data Centers, LLC and Phoenix Data Center Holdings, LLC v. City of Gallatin and Gallatin Department of Electricity, (M.D. Tenn. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

CITY OF GALLATIN, ) ) Plaintiff, ) ) CASE NO. 3:24-CV-00868 v. ) ) JUDGE RICHARDSON GALLATIN DATA CENTERS, LLC, ) ) Defendant. )

GALLATIN DATA CENTERS, LLC and ) PHOENIX DATA CENTER HOLDINGS, ) LLC ) ) Counter-Plaintiffs, ) ) v. ) ) CITY OF GALLATIN, and GALLATIN ) DEPARTMENT OF ELECTRICITY ) ) Counter-Defendants. ) )

MEMORANDUM OPINION Pending before the Court is a Renewed Motion for Judgment on the Pleadings (Doc. No. 34, “Motion”) filed by Plaintiff/Counter-Defendant, City of Gallatin, Tennessee (“City”). Via the Motion, the City seeks judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(c) on the grounds that as a matter of law, it is entitled both to specific performance (its own claim) and to dismissal of the counterclaims filed by Gallatin Data Centers, LLC (“GDC”) and Phoenix Data Centers Holdings, LLC (“PDC”) (collectively, “Counter-Plaintiffs”). Counter- Plaintiffs filed a response in opposition to the Motion (Doc. No. 36, “Response”), whereafter the City filed a reply in support of the Motion (Doc. No. 40, “Reply”).1 For the reasons provided herein, the Court will DENY the Motion.

1 The City attempts to raise new arguments in its Reply and to that end attaches four exhibits to its Reply (“Exhibits”). The Sixth Circuit has consistently held that a reply brief is not a proper place to introduce arguments for the first time. See Sanborn v. Parker, 629 F.3d 554, 579 (6th Cir. 2010) (“We have consistently held, however, that arguments made to us for the first time in a reply brief are waived.” (citing Am. Trim, L.L.C. v. Oracle Corp., 383 F.3d 462, 477 (6th Cir. 2004))); Scottsdale Ins. Co. v. Flowers, 513 F.3d 546, 553 (6th Cir. 2008) (“[W]e have found issues to be waived when they are raised for the first time in . . . replies to responses.”). It logically follows, that a reply brief is also not the proper place to attach exhibits for consideration for the first time. Cf Tankesly v. Centurion of Tennessee, LLC, No. 1:23-CV-90- TAV-SKL, 2024 WL 4682699, at *4 (E.D. Tenn. Nov. 5, 2024) (“Plaintiff’s attempt to raise new arguments and present new proof to support [his motion] in his reply are improper.” (citing Scottsdale Ins. Co., 513 F.3d at 553 (noting that it is improper for a party to present new proof or raise new arguments in a reply, and that courts therefore treat arguments that a party raises for the first time in a reply as waived) (citation omitted))); Bragg v. Staff, No. 1:16-CV-1271, 2019 WL 5273761, at *1, n.3 (W.D. Mich. July 23, 2019) (“A reply brief is not the place to present new evidence.” (citing Perkins v. Rock-Tenn Servs., Inc., 700 F. App’x 452, 460 (6th Cir. 2017); Key v. Shelby Cnty., 551 F. App’x 262, 265 (6th Cir. 2014))), report and recommendation adopted, No. 1:16-CV-1271, 2019 WL 4409486 (W.D. Mich. Sept. 16, 2019); Parks v. Hillsdale Cmty. Health Ctr., No. 1:98-CV-204, 1999 WL 893852, at *2 (W.D. Mich. May 20, 1999) (declining to consider new evidence attached to a reply brief). Importantly, the Undersigned has previously explained the following:

Despite the general rule, the Court realizes that some arguments are appropriately considered even if first raised in the movant’s reply. Specifically, such an argument can (and should) be considered if it was raised in the non-movant’s response to the motion, regarding an issue that the movant in all fairness should not have been expected to raise in its initial brief (since, after all, a movant is not required, and generally is not allowed sufficient briefing pages, to make a pre-emptive argument against every single point that might be made in the non-movant’s response).

Archambeault v. Wyndham Vacation Ownership, Inc., No. 3:20-CV-01044, 2021 WL 6496827, at *5 n.14 (M.D. Tenn. July 14, 2021) (Richardson, J.). The Court will not belabor the point, but it has specifically determined that the Exhibits should have been filed with, and corresponding arguments should have been made, in the first brief. Therefore, the Court will not consider the new arguments nor the Exhibits that the City presented for the first time in its Reply when ruling on the Motion. FACTS AS ALLEGED IN GDC’S ANSWER AND THE AMENDED COUNTERCLAIMS2 A. GDC’s Purchase of the Property The City established the Gallatin Industrial Center and recorded restrictive covenants applicable to the Gallatin Industrial Center in Record Book 3912, page 566, Register’s Office for Sumner County, Tennessee (“Restrictive Covenants”). (Doc. No. 31 at p. 6, ¶ 4;3 Doc. No. 1-1 at

¶ 4). In or around February 2022, GDC began considering the Gallatin Industrial Center as a potential site for a new data center. (Doc. No. 31 at p. 7, ¶ 9). In or around March of 2022, GDC began discussing power needs for the new data center with the Gallatin Department of Electricity.4 (Id. at p. 7, ¶ 11). “On April 20, 2022, Mark Kimbell of the Gallatin Department of Electricity signed a letter5 promising that [the Gallatin Department of Electricity] would be able to handle

2 The facts contained in this section come from the Answer filed by GDC and the counterclaims filed by Counter-Plaintiffs (Doc. No. 31, “GDC’s Answer and Counter-Plaintiffs’ Amended Counterclaims”). For purposes of the instant Motion and pursuant to the typical mechanisms of assessing motions under Federal Rule of Civil Procedure 12(c), the Court accepts the facts alleged in GDC’s Answer and Counter-Plaintiffs’ Amended Counterclaims as true. But the Court does not accept as true any legal conclusions (even if couched as facts). As for any representation that the Court is not accepting as true, the Court generally identifies it by qualifying it (as, for example, by “GDC alleges” or “Counter-Plaintiffs allege”) to denote that it is not being taken as true but rather is set forth to indicate what GDC/Counter-Plaintiffs claim to be true. Throughout this Order, except as indicated in the next sentence, the Court forgoes any such qualifiers for any fact that it is accepting as true, stating those facts without qualification even with the awareness that any such alleged fact may ultimately prove false. Having said that, at times when assessing whether GDC/Counter-Plaintiffs have alleged factual matter sufficient to deny the Motion, the Court does point out that it is basing its assessment on the facts alleged in GDC’s Answer and Counter-Plaintiffs’ Amended Counterclaims; in that particular context, the Court does use the phrase “GDC alleges” or “Counter- Plaintiffs allege” to proceed the facts alleged, even though the Court is taking those facts as true for purposes of the Motion.

3 Because Docket No. 31 (i.e., GDC’s Answer and Counter-Plaintiffs’ Amended Counterclaims) contains two sets of numeration for paragraphs (one set for the portion of the document that reflects GDC’s Answer (Doc. No. 31 at pp 1-5) and one set for the portion of the document that reflects the Counterclaims (id. at pp. 6-22)), the Court—when citing to particular portions of Docket No. 31—will cite to both the page number and the paragraph number being referred to on the specific page number.

4 “The Gallatin Department of Electricity is the electricity service distributor for the City [], including for the Property.” (Doc. No. 31 at p. 7, ¶ 10).

5 The aforementioned letter stated the following: GDC’s power needs at the potential site of its data center.” (Id. at p. 7, ¶ 13).

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City of Gallatin v. Gallatin Data Centers, LLC; Gallatin Data Centers, LLC and Phoenix Data Center Holdings, LLC v. City of Gallatin and Gallatin Department of Electricity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-gallatin-v-gallatin-data-centers-llc-gallatin-data-centers-llc-tnmd-2026.