Qualified Immunity for Outside Government Counsel and Retaliatory Client Pressure:
Commentary on James A. DeLanis v. Metropolitan Government of Nashville & Davidson County

I. Introduction

This Sixth Circuit decision sits at the intersection of three important strands of constitutional doctrine:

the scope of qualified immunity and whether it extends to private law firms acting as outside counsel to a government;
the reach of First Amendment retaliation principles when a public official uses economic client pressure on a private employer; and
the procedural mechanics of appealing a denial of qualified immunity at the motion-to-dismiss stage.

The factual backdrop is local politics in Nashville. In 2020, the Metropolitan Government of Nashville and Davidson County (“Nashville”) enacted a substantial property tax increase. Citizen opponents pursued a charter referendum to repeal the increase and to limit future hikes. The Davidson County Election Commission (“Commission”)—on which plaintiff James A. DeLanis served as chair—had to determine whether the referendum could go on the ballot. Nashville, through its council and officials, aggressively opposed those efforts.

The flashpoint for this litigation arose when:

Robert J. Mendes, a Nashville at-large councilmember, publicly and privately pressed against the referendum and harshly criticized the Commission’s actions; and
Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. (“Baker Donelson”), a private law firm serving as Nashville’s outside counsel, fired DeLanis from the firm after city officials allegedly threatened to pull municipal business if he continued to support the referendum in his Commission role.

DeLanis then brought a 42 U.S.C. § 1983 action alleging First Amendment retaliation (and related claims) against Mendes, Baker Donelson, and Nashville. The district court denied qualified immunity to Mendes and held Baker Donelson ineligible for the defense as a private entity.

In a published opinion by Chief Judge Sutton (joined by Judge Gibbons), the Sixth Circuit:

Affirmed the denial of qualified immunity to Mendes;
Reversed as to Baker Donelson, holding that the firm is eligible for qualified immunity and that it did not violate clearly established law; and
Remanded for further proceedings consistent with that disposition.

Judge Clay dissented as to Baker Donelson, arguing that extending qualified immunity to a private law firm for an internal employment decision conflicts with longstanding Sixth Circuit and Supreme Court precedent and distorts the purpose of the doctrine.

II. Summary of the Opinion

A. Procedural Posture and Jurisdiction

Mendes and Baker Donelson appealed the district court’s denial of qualified immunity at the Rule 12(b)(6) stage. The court:

Invoked the collateral order doctrine to exercise interlocutory jurisdiction over the qualified immunity denials (citing Mitchell v. Forsyth and Ashcroft v. Iqbal); and
Rejected plaintiff’s reliance on Johnson v. Jones, stressing that Johnson limits appellate review of fact-based immunity denials at summary judgment, not at the pleading stage where well-pleaded facts are assumed true.

B. Qualified Immunity Eligibility

The majority held:

Mendes, as a city councilmember sued in his individual capacity, is plainly eligible for qualified immunity.
Baker Donelson, as Nashville’s outside counsel, is also eligible for qualified immunity for acts undertaken while serving the government client—even though it is a private law firm.

The court emphasized that eligibility turns on the function performed, not on job title or organizational form: a private lawyer doing work “at the behest of the sovereign” may claim qualified immunity just as much as in-house government counsel.

C. Clearly Established Law and Merits of the First Amendment Claims

Mendes: Taking the complaint’s allegations as true, the court held that Mendes’s conduct did violate clearly established First Amendment law.
- DeLanis’s advocacy as Commission chair regarding the referendum was assumed to be protected speech.
- Mendes’s alleged threats to pull municipal business from Baker Donelson, with the reasonably foreseeable result of DeLanis’s firing, constituted an adverse action that would deter an ordinary person from speaking.
- Sixth Circuit precedent already clearly established that a public official may not cause someone to be fired from private employment in retaliation for protected political speech (especially Paige v. Coyner and Thaddeus-X v. Blatter).
Baker Donelson: The court did not decide definitively whether the firm’s conduct violated the First Amendment; instead it focused on the “clearly established” prong.
- The court deemed the fact pattern—a private law firm, serving as government counsel, firing a lawyer to protect its client base after the client objected to the lawyer’s public official speech—as “unique” and unaddressed in existing case law.
- The majority could identify no precedent that would have made it clear to a reasonable law firm that this conduct was unconstitutional.
- Accordingly, Baker Donelson received qualified immunity on the federal § 1983 damages claims, even assuming state action.

D. The Dissent

Judge Clay dissented solely as to Baker Donelson. He argued:

Qualified immunity is, under long-standing Sixth Circuit doctrine, a personal defense available only to natural-person government officials sued in their individual capacities.
Private entities, especially for‑profit firms managing internal employment matters motivated by their own business interests, lie outside the core purposes of qualified immunity as articulated in Wyatt v. Cole and Richardson v. McKnight.
Filarsky v. Delia and Cullinan v. Abramson do not support a broad rule that all private attorneys and law firms representing the government enjoy qualified immunity, particularly with respect to their internal human resources decisions.

Clay would have affirmed the district court’s refusal to extend the defense to Baker Donelson and allowed the First Amendment claim against the firm to proceed.

III. Detailed Analysis

A. Precedents and Doctrinal Framework

1. Qualified Immunity Generally

The majority anchors its qualified immunity framework in familiar Supreme Court precedents:

Harlow v. Fitzgerald, 457 U.S. 800 (1982) – established the modern, objective test. Officials are immune so long as they do not violate “clearly established statutory or constitutional rights of which a reasonable person would have known.” The Court abandoned earlier subjective “good faith” inquiries.
Mitchell v. Forsyth, 472 U.S. 511 (1985) – confirmed that qualified immunity is immunity from suit, not just from liability, and is therefore immediately appealable under the collateral order doctrine.
Pearson v. Callahan, 555 U.S. 223 (2009) – allows courts to skip the underlying constitutional question and decide only the “clearly established” prong.
Tolan v. Cotton, 572 U.S. 650 (2014) – reiterates that qualified immunity protects government officials from damages but does not bar other forms of relief.

The Sixth Circuit also cites its own recent formulations, including Moore v. Oakland County (2025), emphasizing that:

Qualified immunity is a defense for “officers” or those “serving the public,”
applies to discretionary functions, and
focuses on functional roles rather than formal titles.

2. Qualified Immunity for Private Actors

The most consequential part of the opinion concerns whether, and under what circumstances, a private actor may invoke qualified immunity.

The majority relies on three key cases:

Richardson v. McKnight, 521 U.S. 399 (1997)
The Supreme Court denied qualified immunity to guards employed by a private prison company that operated a state facility under contract. The Court emphasized:
- The firm was a for‑profit company performing a “major, lengthy administrative task” for the state;
- It operated with “limited direct supervision” and in competition with other private firms; and
- Historically, the common law did not recognize broad immunity for such large-scale private contractors.
Still, the Court cautioned that its decision was narrow and did not foreclose all immunity claims by private individuals.
Cullinan v. Abramson, 128 F.3d 301 (6th Cir. 1997)
Sixth Circuit precedent directly on point: outside counsel to the City of Louisville were sued under § 1983 for their participation in allegedly wrongful litigation strategies. The court held:
- Private lawyers “performing services at the behest of the sovereign” could invoke qualified immunity,
- Because the rationales for the doctrine applied just as much to outside counsel as to in‑house counsel, and
- The lawyers’ “outside counsel” status did not disqualify them.
Filarsky v. Delia, 566 U.S. 377 (2012)
The Supreme Court held that a part‑time private attorney hired by a city to conduct an internal investigation could claim qualified immunity. The Court:
- Looked to historical practice showing that individuals temporarily retained by the government to perform public functions commonly enjoyed the same protections as regular officials;
- Dismissed rigid public/private distinctions, stressing that immunity should not depend on payroll status; and
- Reasoned that denying immunity to such private actors would deter skilled professionals from assisting the government.

The majority combines Cullinan and Filarsky to reaffirm that private lawyers and law firms working for governments can be eligible for qualified immunity when sued over actions taken “in service of” those clients and in performance of governmental functions.

By contrast, the dissent points to a different cluster of cases:

Wyatt v. Cole, 504 U.S. 158 (1992) – refused to extend qualified immunity to private parties using prejudgment replevin statutes to advance their own interests because they were not serving public functions and the ordinary rationales for immunity (avoiding undue deterrence from public service) did not apply.
Richardson v. McKnight again – emphasizing that private firms running prisons for profit, in competitive markets, do not receive qualified immunity.
Sixth Circuit precedents like United Pet Supply, Inc. v. City of Chattanooga, 768 F.3d 464 (6th Cir. 2014), and Nugent v. Spectrum Juvenile Justice Services, 72 F.4th 135 (6th Cir. 2023), which reiterate that qualified immunity is generally a personal defense for government officials and is unavailable to governmental entities and Monell defendants.

Judge Clay stresses that these cases, combined with the historical and policy analysis required by McCullum v. Tepe, counsel against extending immunity to a private law firm for a purely internal employment decision driven by its own business interests, even if that decision is influenced by a government client.

3. State-Actor Liability vs. Availability of Qualified Immunity

A subtle but critical distinction in the majority opinion: state action and eligibility for qualified immunity are logically separate.

On the one hand, if a private firm is alleged to act “under color of state law” (e.g., by implementing a government policy or acting jointly with officials), it may face § 1983 liability.
On the other hand, if that is true, the Court reasons, it also should be able to claim the same defenses available to public actors, including qualified immunity, at least when it is being sued in a capacity analogous to that of an individual officer.

This is the “bitter and the sweet” rationale—if private actors are exposed to the burdens of § 1983 as quasi‑state actors, they should also enjoy the protections state actors have. Filarsky explicitly endorses this symmetry.

The dissent, however, draws a firmer bright line: eligibility for qualified immunity should be confined to natural-person government officials sued individually, and not extended to private corporations or firms—even if they are state actors for liability purposes.

B. Mendes and the First Amendment Retaliation Claim

1. Protected Speech

The opinion largely sidesteps complex questions about whether a public official’s official acts can be characterized as “speech” of the sort protected by the First Amendment. Cases like Garcetti v. Ceballos, Doe v. Reed, and Nevada Commission on Ethics v. Carrigan raise issues about whether official decisionmaking (voting, policymaking) is personal expression or simply state action.

But here:

Neither Mendes nor Baker Donelson disputed that DeLanis’s advocacy and votes as Commission chair regarding the referendum constituted protected activity for purposes of the motion to dismiss.
The majority therefore accepts this premise and does not explore whether, doctrinally, the Commission-chair activity stands on the same footing as “ordinary” citizen speech.

2. Adverse Action and “Ordinary Firmness”

To plead First Amendment retaliation, a plaintiff must show that the defendant took an adverse action that would “dissuade a person of ordinary firmness” from engaging in the protected speech (Thaddeus-X; Cunningham v. Blackwell).

Here, the majority reasons that:

Mendes’s alleged conduct—threatening that Nashville would pull its substantial legal business from Baker Donelson unless it “influenced” or stopped DeLanis’s Commission actions—would clearly deter an ordinary person in DeLanis’s position.
The reasonably foreseeable consequence of such threats to the firm’s business was the loss of DeLanis’s job. That loss, in turn, is a paradigmatic adverse action, as already held in multiple Sixth Circuit cases.

The majority leans heavily on Paige v. Coyner, 614 F.3d 273 (6th Cir. 2010), where a county official, angered by a consultant’s opposition to a highway project, contacted the consultant’s private employer and falsely described her statements, with the intent and effect of having her fired. Paige held that such conduct states a valid First Amendment retaliation claim: “[l]osing one’s job and accompanying benefits is certainly severe enough” to deter speech.

3. Causation and Plausibility

The causation inquiry asks whether there is a plausible link between:

the plaintiff’s protected speech, and
the defendant’s adverse action (here, Mendes’s pressure that led to the firing).

At the motion-to-dismiss stage, the court:

Accepts as true DeLanis’s allegations that:
- Nashville “officials” threatened to pull business from Baker Donelson;
- Those officials “included” Mendes, or acted at his direction or in concert with him; and
- Those threats caused the firm to terminate DeLanis.
Holds that it is plausible (under Twombly) to infer Mendes’s participation, given:
- His leading role in opposing the referendum;
- His public “berating” of the Commission, and specifically of DeLanis;
- His public letter accusing DeLanis of “hyper-partisan” conduct and “anti‑democracy” actions; and
- His position of influence on the very council that controlled the city’s legal contracts.

Mendes’s suggestion that Baker Donelson might have misunderstood or overreacted to innocuous communications is deemed speculative; such alternative explanations are for summary judgment or trial, not for Rule 12(b)(6).

4. Clearly Established Law as Applied to Mendes

On the “clearly established” prong, the majority’s analysis is straightforward:

Collectively, Thaddeus-X, Paige, Kubala v. Smith, Stockdale v. Helper, and similar cases clearly hold that:
- Causing someone to lose employment in retaliation for protected speech violates the First Amendment.
- This is true whether the official is the direct employer or uses outside influence (such as pressuring a private employer) to effect the firing.
The fact that DeLanis held a public office (Commission chair) while working in private practice does not meaningfully distinguish this case from Paige and its ilk; the core harm—job loss due to protected speech—is the same.

Thus, Mendes is not entitled to qualified immunity at this stage; the claim against him proceeds.

C. Baker Donelson: Private Law Firm, State Actor, and Qualified Immunity

1. Eligibility for Qualified Immunity

The majority first determines that Baker Donelson is eligible to assert qualified immunity by characterizing the firm’s role as one of outside government counsel performing public functions:

Baker Donelson was Nashville’s outside counsel “at all times relevant.”
City officials explicitly asked the firm to “aid and assist” in preserving the tax increase “by influencing DeLanis as a Commissioner.”
According to the complaint, Nashville’s policy choice (preserving the tax increase) and its anti-referendum strategy were intertwined with Baker Donelson’s actions in firing DeLanis “pursuant to” Nashville’s anti-referendum policy.
DeLanis himself alleged that his removal “should be attributed to the city,” underscoring the state-actor theory.

On this basis, the majority:

Analogizes to Cullinan (outside litigation counsel acting at the city’s behest) and Filarsky (part‑time private attorney retained to conduct an internal investigation);
Rejects any formal distinction based on the firm’s corporate status (professional corporation vs. partnership), reading Cullinan as driven by function, not form; and
Interprets Nugent and United Pet Supply as limited to:
- Monell and official-capacity claims (where entities cannot claim qualified immunity), and
- Not as pronouncing a global bar on private actors raising the defense when sued in functional equivalents of individual capacity.

The dissent forcefully objects here, pointing out that:

Sixth Circuit decisions (e.g., Scott v. Clay County, Benison v. Ross, United Pet Supply) repeatedly describe qualified immunity as a defense for “individual government officials” and only “natural persons.”
Richardson and Wyatt suggest skepticism about extending immunity to private for‑profit firms, particularly when they are pursuing their own business interests.
McCullum v. Tepe indicates that courts should undertake a historical and policy-based inquiry before granting immunity to private actors—an analysis the dissent believes the majority bypasses.

2. Clearly Established Law as Applied to Baker Donelson

Turning to whether Baker Donelson violated clearly established law, the majority stresses the novelty of the situation:

The firm:
- Was a private, for‑profit law firm with many clients;
- Acted in response to explicit pressure from one of its major governmental clients; and
- Fired an employee whose off‑the‑clock public official role (Commission chair) had become politically unacceptable to that client.
The firm’s alleged motivation was protection of its business relationship, not animus toward the content of the speech per se.
The firm did not itself take a public position against the referendum.

The court notes that none of the cases cited by DeLanis clearly govern such a scenario:

Paige, Anders v. Cuevas, MacIntosh v. Clous, and Zilich v. Longo involve public officials retaliating against private actors, not private firms managing internal employment under client pressure.
Anders, for example, involved the state police removing a towing company from a call rotation in retaliation for speech; the company was the victim, not the alleged perpetrator.
No case addresses whether a law firm violates the First Amendment by terminating an employee at the behest of a government client whose interests the employee’s public role is perceived to harm.

Because qualified immunity demands either:

a case with “facts similar enough that it squarely governs” (Moore), or
an obvious constitutional violation of the sort identified in Hope v. Pelzer,

the majority concludes that the law was not clearly established for Baker Donelson.

As to the “obviousness” exception:

Hope v. Pelzer and Sexton v. Cernuto involved extreme conduct—torturous conditions of confinement and enabling sexual assault within a work-release program, respectively.
The majority finds those cases qualitatively different from a law firm’s economic decision to retain a lucrative client at the cost of an employee’s position, even if the decision responds to governmental retaliation.

Thus, without deciding whether Baker Donelson’s conduct was unconstitutional, the court holds that a reasonable law firm in that position would not have had fair notice that its conduct violated the First Amendment, and qualified immunity therefore applies.

3. The Dissent’s Critique

Judge Clay’s dissent contends:

Historically and doctrinally, qualified immunity is reserved for natural persons who hold government office and exercise public power directly;
Private firms, even when they have government clients or perform government‑like tasks, should not be insulated from suit for their own private, profit-driven decisions—particularly internal employment decisions;
The majority’s functional approach blurs critical lines, allowing any private firm carrying out some governmental work to cloak itself in immunity across a broad swath of its operations; and
This decision undermines the accountability goals of § 1983 by shielding private actors who help implement government retaliation against speech.

Clay stresses that:

Baker Donelson’s motive in firing DeLanis was, by its own admission, purely economic—to preserve its client relationship—not to carry out any governmental duty;
That distinction matters: the firm was not “principally concerned with enhancing the public good” but rather with its bottom line, making it akin to the private actors in Wyatt and Richardson, not to the temporary investigator in Filarsky or litigation counsel in Cullinan directly executing legal tasks on the city’s behalf;
Merely acting “because the government asked” does not transform a private entity’s employment decision into a public function, nor should it automatically import qualified immunity.

From this perspective, the majority’s approach risks giving private firms a powerful shield—discouraging suits even when they knowingly participate in governmental retaliation—without the countervailing public-service motivations that justify immunity for traditional officials.

IV. Impact and Implications

A. For Private Law Firms and Government Contractors

The decision has immediate significance for private entities—especially law firms—that serve as outside counsel or contractors for government actors:

In the Sixth Circuit, such firms are now more firmly positioned to argue that when they act as state actors (e.g., implementing government legal strategies or actions “at the behest of the sovereign”), they can assert qualified immunity in § 1983 damages actions.
The case narrows plaintiffs’ ability to recover monetary damages from these private actors for constitutional torts connected to governmental clients, at least where the law is not clearly established.
However, the decision does not foreclose:
- Injunctive or declaratory relief against such firms;
- Direct damages suits against the government entities themselves under Monell, where appropriate; or
- State-law claims (e.g., wrongful termination, state constitutional violations), which remain unaffected by federal qualified immunity doctrine.

The majority carefully cabined its holding to this record, but in practice, firms representing public entities will likely rely on this opinion to seek dismissal or early summary judgment on § 1983 damages claims.

B. For Public Officials Using Economic Pressure

As to public officials like Mendes, the opinion:

Unambiguously reinforces that using economic leverage—threatening to pull government contracts or business—to induce a private employer to fire someone for protected political speech violates clearly established law.
Confirms that a city councilmember’s political disagreement with an official’s or citizen’s speech does not justify behind-the-scenes efforts to orchestrate job loss via client pressure.
Signals that at least the individual official can be personally liable, even if the cooperating private firm escapes damages through qualified immunity.

C. For Mixed-Role Officials and Conflict-of-Interest Contexts

The case also illustrates the vulnerability of individuals who wear two hats:

As public officials (e.g., commission chairs, board members), and
As private employees in firms that work with government clients affected by their public decisions.

Such individuals face:

Potential conflict-of-interest dilemmas, and
Heightened risk of retaliation via the private employer, driven by client dissatisfaction.

This opinion:

Protects their speech interests to some extent by affirming liability against the government official who applies the pressure; but
Simultaneously makes it harder to recover damages from the employer that capitulates to client demands, at least without a closely analogous case on point.

D. Future Litigation and Doctrinal Development

Several issues are left unresolved or primed for further development:

Substantive First Amendment question as to the firm: The court assumed without deciding that Baker Donelson was a state actor and that firing an employee in this context could potentially implicate First Amendment concerns. Future cases may have to confront, more directly, whether and how the First Amendment constrains private employers who fire employees to appease governmental clients.
Scope of “public function” for private lawyers: The decision suggests that staffing and HR decisions linked to government policy might sometimes be seen as part of the public function. The dissent warns this may be too broad. Later panels will likely refine where the line lies.
Tension with prior Sixth Circuit precedent: The dissent highlights prior published statements limiting qualified immunity to individual government officials. Reconciling those formulations with the functional approach here may become a subject for en banc or Supreme Court review.
Incentives: By insulating firms more readily than individual officials, the doctrine may:
- Encourage public officials to leverage private intermediaries to implement retaliation, knowing the private actors are shielded;
- Or, conversely, make firms more comfortable resisting improper pressure, knowing that First Amendment rules are not clearly defined in this space and they may have a qualified-immunity defense if sued as state actors.

V. Complex Concepts Simplified

1. Qualified Immunity

A legal doctrine that protects government officials (and some private actors serving the government) from money-damages liability in civil-rights suits under § 1983 if:
- They did not violate a constitutional right; or
- The right was not clearly established at the time of their conduct.
It aims to protect legitimate decisionmaking and avoid deterring qualified individuals from public service due to fear of personal liability.
It does not bar claims for injunctive or declaratory relief.

2. “Clearly Established Law”

A right is “clearly established” if:
- Existing precedent (from the Supreme Court or relevant circuit) has addressed a similar fact pattern, such that every reasonable official would understand the conduct is unlawful; or
- In rare cases, the violation is so egregious that it is obviously unconstitutional even without a case on point (the Hope v. Pelzer “obviousness” exception).
Courts generally require more than a broad statement of a legal principle; they look for specific guidance in prior decisions.

3. State Action

§ 1983 applies only to actions taken “under color of state law.”
A private entity can qualify as a “state actor” if:
- It performs a function that is traditionally and exclusively public (public function test);
- It acts jointly with or under the direction of government officials (joint action test); or
- Its conduct is fairly attributable to the state under other recognized tests.

4. First Amendment Retaliation

To state a claim, a plaintiff must show:

He engaged in protected speech or expressive conduct;
The defendant took an adverse action that would deter a person of ordinary firmness from continuing to engage in the protected activity; and
The adverse action was motivated, at least in part, by the protected conduct (causal link).

5. Monell Liability vs. Individual Capacity

Monell claims target municipalities or other entities for constitutional violations caused by official policies, customs, or practices. These entities cannot assert qualified immunity.
Individual-capacity claims target specific officials (or analogous actors) personally for their conduct. Qualified immunity is generally available in this context.
The central dispute in this case is whether a private law firm, treated as a state actor, falls into the latter category and may claim qualified immunity.

6. Collateral Order Doctrine

A narrow exception to the rule that only final judgments can be appealed.
Denials of qualified immunity are immediately appealable because the doctrine protects officials from being sued at all, not merely from ultimate liability.
However, this interlocutory review is limited, especially at summary judgment, to legal questions (not disputed facts).

VI. Conclusion: Significance of the Opinion

James A. DeLanis v. Metropolitan Government of Nashville establishes or reinforces several key propositions in Sixth Circuit law:

Retaliatory client pressure is constitutionally actionable.
A public official who uses the government’s economic influence over private firms—in this case, legal contracts—to engineer a critic’s firing because of protected speech may be held individually liable under the First Amendment. This extends the logic of cases like Paige v. Coyner to the context of government–counsel relationships.
Outside government counsel can claim qualified immunity.
Building on Cullinan and Filarsky, the opinion confirms that private law firms representing government entities can be eligible for qualified immunity when sued as state actors for actions taken in connection with their governmental work—even for personnel decisions intertwined with that representation.
But the law remains unsettled regarding employer liability in this niche context.
While Mendes’s retaliatory pressure clearly violated established First Amendment principles, the court finds no precedent squarely addressing whether a private firm like Baker Donelson commits a First Amendment violation by capitulating to such pressure. On that uncertainty, the firm receives immunity from damages.
Doctrinal tensions are sharpened, not resolved.
The dissent highlights the friction between this functional extension of qualified immunity to private entities and earlier Sixth Circuit language limiting the defense to natural-person government officials. The opinion will likely be a touchstone in future disputes about the proper boundaries of qualified immunity for private actors.

In the broader constitutional landscape, this case underscores a recurring pattern: the expansion of immunity doctrine often outpaces the development of clearly articulated limits on state-action liability for private partners of the government. For practitioners and scholars, DeLanis is significant both as a reaffirmation of robust protection against First Amendment retaliation by officials and as a notable step in extending qualified immunity to private outside counsel in the governmental sphere.

Qualified Immunity for Outside Government Counsel and Retaliatory Client Pressure: Commentary on James A. DeLanis v. Metropolitan Government of Nashville & Davidson County