In February 2017, in Memphis, TN, news broke of a security list at City Hall that named dozens of Memphians associated with recent protests, particularly those associated with #BlackLivesMatter and other social justice movements. The mysteriously sourced list implicated the city and the police department in the violation of a forty-year old consent decree which prohibited political surveillance.

The Kendrick Consent Decree of 1978 resolved a battle between the city and the ACLU and ended an era of unchecked police power to investigate and keep records on political activists in the Civil Rights Movement, the anti-war movement, and others. The ACLU and the city were back in court through 2018, when the city was found to have violated the Kendrick Consent Decree and a federal judge established a monitor committee of legal experts.

Because of this court decision, Memphis has been developing policies and guidelines for police investigations that touch upon political expression and free speech.