Home Sweet Business: Victory For Garage-Based Entrepreneurs In Nashville
In the course of litigation, there are always twists, turns, and setbacks. But IJ and our clients are dedicated to the long-term fight for individual freedom. That dedication makes victory—such as the win we recently scored for Lij Shaw and Pat Raynor in Nashville—even sweeter.
Pat is a hairstylist and cosmetologist. Shortly after her husband passed away, she built a state-licensed single-chair salon in her garage so she could work from home as she got older. But just a couple of months after she opened, the city shut her down.
Lij is a professional record producer. In 2005, he built a soundproof recording studio in his garage so he could work from home and raise his daughter. But in 2015—shortly after an album mixed in his studio won a Grammy—the city shut him down, too.
Having a home studio or salon was perfectly legal. But Nashville banned home-based businesses from having clients. Except, of course, Nashville also had a web of carveouts for certain privileged businesses. We even tried to help Lij and Pat secure one of these exceptions through an 18-month rezoning process that was frustrated by objections from a small group who lived nowhere near Lij and Pat.
We then filed our case in late 2017 and spent two years building a compelling record that showed there was no reason to prevent Lij and Pat from operating their home-based businesses. But the trial court determined that those facts did not matter; the government won. This is often par for the course in economic liberty and property rights cases at the trial court level, so we appealed.
Then COVID-19 happened. The city told everyone to work from home, only to realize its home-based business rules made that illegal in most instances. So they reformed the law to allow a small number of customers—but imposed onerous regulatory burdens on anyone who wasn’t already operating under the carveout. For instance, business owners had to keep detailed logs of every person who visited and make those logs available to the city without a warrant.
This effectively created two separate classes of home-based businesses subject to vastly different requirements. Meanwhile, it took three years and a trip to the Tennessee Supreme Court to revive our case.
The landscape of the case had changed. But that meant nothing to the trial court, which again insisted that facts don’t matter and again ruled against us. More determined than ever, IJ appealed once more.
In August 2025, we finally got a decision—and it was worth the wait. A unanimous appellate court panel declared that there was “no rational reason” to regulate Lij and Pat more onerously than other home-based businesses.
We are not quite done yet. The city could appeal to the state’s high court. Or the city could decide to work with us to amend its ordinance. Regardless, this case is bigger than just Lij and Pat. It affirms—as we have been saying since the beginning—that facts matter. Government can’t place unreasonable burdens on businesses or treat them differently without any evidence. It also builds momentum in our growing Zoning Justice Project.
Not just anyone can fight city hall for a decade. Most people could never afford to persevere through all the twists and turns over so many years. But because of the dedication of clients like Lij and Pat, and of our supporters, IJ can fight that long-term fight. And in the end, we are all more free because of it.
Paul Avelar is a senior attorney and managing attorney of IJ’s Arizona office.
Related Case
Economic Liberty | Private Property | Small and Home-Based Business | Zoning Justice Project
Nashville Home-Based Business
Lij Shaw and Pat Raynor both run successful businesses within their own homes – one a recording studio, the other a hair salon. But one day, the city of Nashville threatened them with fines unless…
Subscribe to get Liberty & Law magazine direct to your mailbox!
Sign up to receive IJ's bimonthly magazine, Liberty & Law, along with breaking news updates about the Institute for Justice's fight to protect the rights of all Americans.