Paper highlights statewide pro bono effort

An article today in the Memphis Daily News provides an excellent overview of the TBA's 4ALL campaign and service projects planned in the Memphis area on April 4. There are currently more than 25 events scheduled around the state on 4/4. TBA President Buck Lewis sums up the success of the effort thus far: "If somebody had told me three months ago we'd have 27 separate events from Bristol to Memphis, I'd have told them they were crazy." Read the article

Learn more about the campaign and how to get involved

TODAY'S OPINIONS
Click on the category of your choice to view summaries of today’s opinions from that court, or other body. A link at the end of each case summary will let you download the full opinion in PDF format. To search all opinions in the TBALink database or to obtain a text version of each opinion, go to our OpinionSearch page. If you have forgotten your password or need to obtain a password, you can look it up on TBALink at the TBA's Membership Central.

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You can obtain full-text versions of the opinions two ways. We recommend that you download the Opinions to your computer and then open them from there. 1) Click the URL at end of each Opinion paragraph below. This should give you the option to download the original document. If not, you may need to right-click on the URL to get the option to save the file to your computer. 2) Do a key word search in the Search Link area of TBALink. This option will allow you to view and save a plain-text version of the opinion.

BETH ANN MASON v. THADDEAUS SCOTT MASON

Court: TCA

Attorneys:

Darrell L. Scarlett, Murfreesboro, Tennessee, for the appellant, Thaddeaus Scott Mason.

Russ Heldman, Nashville, Tennessee, for the appellee, Beth Ann Mason.

Judge: DINKINS

Following the entry of a final decree in a divorce action, Husband filed a motion to alter or amend the decree, pursuant to Rule 60, Tenn. R. Civ. P., asserting that the parties made a clerical error in the marital dissolution agreement, as a result of which Wife received a higher percentage of marital assets than intended. The trial court denied relief. We affirm the action of the trial court.

http://www.tba2.org/tba_files/TCA/2009/masonb_030409.pdf


STEVEN LAMONT ANDERSON v. STATE OF TENNESSEE

Court: TCCA

Attorneys:

Steven Lamont Anderson, Pro Se. Steven Lamont Anderson, Pro Se. Steven Lamont Anderson, Pro Se.

Robert E. Cooper, Jr., Attorney General and Reporter; Cameron L. Hyder, Assistant Attorney General; and James Pentecost, for the appellee, the State of Tennessee.

Judge: WOODALL

Petitioner, Steven Lamont Anderson, appeals the trial court's summary dismissal of his petition for writ of habeas corpus. After a thorough review, we affirm the judgment of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/andersons_030409.pdf


STATE OF TENNESSEE v. JOEL E. BLANTON

Court: TCCA

Attorneys:

G. Jeff Cherry, Lebanon, Tennessee (on appeal), and Billy K. Tollison, III, Sparta, Tennessee (at trial), for the Appellant, Joel E. Blanton.

Robert E. Cooper, Jr., Attorney General and Reporter; Michael E. Moore, Solicitor General; Elizabeth B. Marney, Assistant Attorney General; Anthony J. Craighead, Interim District Attorney General; and Beth E. Willis, Assistant District Attorney General, for the Appellee, State of Tennessee.

Judge: WEDEMEYER

A White County jury found the Defendant, Joel E. Blanton, guilty of one count of rape of a child and two counts of aggravated sexual battery. The trial court sentenced him to an effective sentence of twenty-four years. On appeal, the Defendant contends: (1) the evidence presented was insufficient to support his convictions on all three counts; (2) the successor judge at the hearing on a motion for new trial improperly concluded that he could sufficiently familiarize himself with the record and act as the thirteenth juror; (3) the trial court erroneously instructed the jury with respect to the required mental state for rape of a child; (4) the trial court erroneously instructed the jury with respect to the required mental state for aggravated sexual battery; and (5) the trial court erroneously instructed the jury with respect to the definition of "knowingly." After a thorough review of the record and the applicable law, we affirm the trial court's judgments.

http://www.tba2.org/tba_files/TCCA/2009/blantonj_030409.pdf


GREGORY HARRIS v. STATE OF TENNESSEE

Court: TCCA

Attorneys:

Gregory Harris, Pro Se, Mountain City, Tennessee.

Robert E. Cooper, Jr., Attorney General and Reporter; Cameron L. Hyder, Assistant Attorney General; Greeley Wells, District Attorney General, and Joseph E. Perrin, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: SMITH

Petitioner, Greg Harris, was convicted in Sullivan County of criminal conspiracy to sell or deliver more than 300 grams of cocaine, possession of more than 300 grams of cocaine for resale within 1000 feet of a school, and two counts of possession of drug paraphernalia. As a result, he was sentenced to an effective sentence of fifty years. On appeal, this Court modified Petitioner's sentences to twenty-four years on each felony charge and reversed the trial court's imposition of consecutive sentences, resulting in Petitioner's effective sentence being reduced from fifty years to twenty-four years. State v. Greg Harris, No. E2003-02834-CCA-R3-CD, 2005 WL 419082, at *1 (Tenn. Crim. App., at Knoxville, Feb. 23, 2005). Petitioner subsequently sought post-conviction relief in a petition that was dismissed by the post-conviction court. The dismissal of that petition was affirmed on appeal. Greg Harris v. State, No. E2006-00406-CCA-R3-PC, 2006 WL 3613608 (Tenn. Crim. App., at Knoxville, Dec. 12, 2006). In October of 2007, Petitioner sought relief via the writ of error coram nobis, alleging that newly-discovered evidence warranted a reversal of his convictions. The trial court dismissed the petition as untimely. Petitioner seeks a review of the trial court's dismissal. We determine that the petition for writ of error coram nobis was untimely and, therefore, affirm the judgment of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/harrisg_030409.pdf


STATE OF TENNESSEE v. KELLY LYNN HODGE

Court: TCCA

Attorneys:

Randall D. Fleming, Kingsport, Tennessee, for the appellant, Kelly Lynn Hodge.

Robert E. Cooper, Jr., Attorney General and Reporter; Matthew Bryant Haskell, Assistant Attorney General; Greeley Wells, District Attorney General, and Kent Chitwood, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: SMITH

The Sullivan County Grand Jury indicted Appellant, Kelly Hodge, for possession of over twenty-six grams of cocaine with intent to sell or deliver. Appellant pled guilty to possession of cocaine with intent to sell or deliver. The trial court sentenced Appellant to three years to be served on probation. During her sentencing hearing, Appellant requested judicial diversion. See T.C.A. section 40-35-313. The trial court heard evidence on Appellant's suitability for judicial diversion but denied her request. Appellant's sole issue on appeal is whether the trial court erred in denying her judicial diversion. After a thorough review of the record, we determine that the evidence supports the trial court's conclusion. Therefore, we affirm the judgment of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/hodgek_030409.pdf


STATE OF TENNESSEE v. TOMMY HOLMES

Court: TCCA

Attorneys:

Claiborne H. Ferguson, Memphis, Tennessee, for the appellant, Tommy Holmes.

Robert E. Cooper, Jr., Attorney General and Reporter; David H. Findley, Assistant Attorney General; William L. Gibbons, District Attorney General; and Amy Weirich, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: GLENN

The defendant, Tommy Holmes, was convicted by a Shelby County jury of aggravated rape, a Class A felony, and sentenced by the trial court as a violent offender to twenty-four years in the Department of Correction. He raised a number of issues in his original direct appeal, including whether the trial court erred in finding that he had forfeited his right to trial counsel. We found no merit in the other claims, but remanded to the trial court with instructions to hold an evidentiary hearing with respect to the forfeiture of counsel issue. See State v. Tommy L. Holmes, No. W2006- 00236-CCA-R3-CD, 2007 WL 1651876 (Tenn. Crim. App. June 7, 2007), perm. to appeal denied (Tenn. Sept. 17, 2007). After holding that hearing, the trial court entered an order finding that the defendant had forfeited the right to counsel by physically assaulting his trial counsel. The defendant now appeals from that order, arguing that his behavior was not sufficiently egregious to warrant the denial of his Sixth Amendment right to counsel. Following our review, we affirm the trial court's order finding that the defendant waived his right to counsel. Having previously found no merit to the defendant's other issues raised on direct appeal, we also affirm his judgment of conviction.

http://www.tba2.org/tba_files/TCCA/2009/holmest_030409.pdf

THOMAS dissenting
http://www.tba2.org/tba_files/TCCA/2009/holmest_DIS_030409.pdf


STATE OF TENNESSEE v. CLARENCE EDWARD MCCALEB

Court: TCCA

Attorneys:

J. Liddell Kirk (on appeal) and Steve Sams (at trial), Knoxville, Tennessee, for the appellant, Clarence Edward McCaleb.

Robert E. Cooper, Jr., Attorney General and Reporter; Leslie E. Price, Assistant Attorney General; Randall E. Nichols, District Attorney General; and Philip Morton, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: WILLIAMS

The defendant, Clarence Edward McCaleb, was convicted of two counts of aggravated rape (Class A felonies), two counts of aggravated robbery (Class B felonies), and two counts of aggravated burglary (Class C felonies). He received a total effective sentence of life plus thirty years. On appeal, the defendant argues that: the evidence was insufficient to support his convictions; his convictions should have been merged; and he was sentenced improperly. After careful review, we conclude that the evidence was sufficient to support the defendant's convictions and find no reversible error in the defendant's sentences. However, some of the defendant's convictions should have been merged, and we remand that single issue to the trial court.

http://www.tba2.org/tba_files/TCCA/2009/mccalebc_030409.pdf


STATE OF TENNESSEE v. ARCHIE RAY MOORE

Court: TCCA

Attorneys:

Andrew Jackson Dearing, Shelbyville, Tennessee, for the appellant, Archie Ray Moore.

Robert E. Cooper, Jr., Attorney General and Reporter; Rachel West Harmon, Assistant Attorney General; Charles Crawford, District Attorney General; and Hollyn Hewgley, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: WELLES

The Defendant, Archie Ray Moore, was convicted of selling .5 grams or more of a substance containing cocaine. The trial court sentenced him as a Range II, multiple offender to nineteen years in the Department of Correction. In this direct appeal, he argues that (1) the State presented evidence insufficient to convict him; and (2) the trial court erred in denying him community corrections and in setting the length of his sentence. After our review, we affirm the judgment of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/moorea_030409.pdf


LARRY J. NOEL v. JOE EASTERLING, WARDEN

Court: TCCA

Attorneys:

Larry J. Noel, Whiteville, Tennessee, Pro Se.

Robert E. Cooper, Jr., Attorney General and Reporter; Rachel West Harmon, Assistant Attorney General; and D. Michael Dunavant, District Attorney General, for the appellee, State of Tennessee.

Judge: WILLIAMS

The petitioner, Larry J. Noel, appeals the Hardeman County Circuit Court's summary dismissal of his pro se petition for the writ of habeas corpus. The petitioner was indicted in 2002 for aggravated assault. On June 7, 2002, he was convicted of the offense of simple assault and sentenced to a term of eleven months and twenty-nine days. In 2008, he filed a pro se petition for writ of habeas corpus, alleging that the sentence imposed for "aggravated assault" was illegal because the trial court was without authority to sentence him to a term of eleven months and twenty-nine days for a felony conviction. The habeas corpus court summarily dismissed the petition, finding that the sentence was proper for misdemeanor assault and that the petitioner was not entitled to relief as he was no longer restrained under the challenged sentence. On appeal, the petitioner argues that the habeas corpus court improperly dismissed the petition in contravention of Tennessee Code Annotated section 29- 21-110 by failing to address the issue of whether the general sessions court had jurisdiction. Following review of the record, we affirm the summary dismissal.

http://www.tba2.org/tba_files/TCCA/2009/noell_030409.pdf


STATE OF TENNESSEE v. JEFF OOLEY

Court: TCCA

Attorneys:

Dan T. Bryant, McMinnville, Tennessee (at trial); and Trenena G. Wilcher, McMinnville, Tennessee (on appeal) for the appellant, Jeff Ooley.

Robert E. Cooper, Jr., Attorney General and Reporter; Melissa Roberge, Assistant Attorney General; Lisa S. Zavogiannis, District Attorney General; and Mark E. Tribble, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: WITT

The defendant, Jeff Ooley, pleaded guilty to two counts of facilitation of attempted second degree murder, see T.C.A. sections 39-11-403; 39-12-101; 39-13-210 (2006), and two counts of aggravated assault, see id. section 39-13-102(a)(1)(B). The defendant applied for judicial diversion, see id. section 40-35- 313; however, the trial court denied his request and sentenced him to serve 365 days in the Warren County Jail with the remainder his effective four-year sentence to be served on probation. The defendant appeals, claiming that the trial court erred in denying judicial diversion. Discerning no error, we affirm the judgments of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/ooleyj_030409.pdf


STATE OF TENNESSEE v. GEORGE C. PEERY, III

Court: TCCA

Attorneys:

Raymond C. Conkin, Jr., Kingsport, Tennessee, for the Appellant, George C. Peery, III.

Robert E. Cooper, Jr., Attorney General and Reporter; Clarence E. Lutz, Assistant Attorney General; Greeley Wells, District Attorney General, and William B. Harper, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: SMITH

Appellant, George C. Peery, III, pled guilty to felony failure to appear, felony escape, possession of drug paraphernalia, and theft of property valued at less than $500. As part of the plea agreement, Appellant received an effective eight-year sentence at 35 percent for the convictions for failure to appear and escape. In addition, Appellant received concurrent sentences of eleven months and twenty-nine days at 75 percent for the drug paraphernalia and theft convictions, to run concurrently to each other but consecutively to the eight-year sentence. The trial court denied alternative sentencing on the basis that Appellant had "too many prior problems." On appeal we determine that the trial court properly denied alternative sentencing. Consequently, the judgments of the trial court are affirmed.

http://www.tba2.org/tba_files/TCCA/2009/peeryg_030409.pdf


STATE OF TENNESSEE v. KALE J. SANDUSKY

Court: TCCA

Attorneys:

John S. Colley, III, Columbia, Tennessee, for the appellant, Kale J. Sandusky.

Robert E. Cooper, Jr., Attorney General; Cameron L. Hyder, Assistant Attorney General; Mike Bottoms, District Attorney General; and Doug Dicus, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: WELLES

This is a direct appeal from a guilty plea pursuant to Rule 37(b)(2) of the Tennessee Rules of Criminal Procedure. The Defendant, Kale J. Sandusky, pleaded guilty to possession of marijuana with the intent to sell and unlawful possession of drug paraphernalia. In his plea agreement, the Defendant attempted to reserve a certified question of law, challenging the trial court's denial of his motion to suppress the evidence seized during the searches of his residence. Because the Defendant has failed to properly certify his issue for review, the appeal is dismissed.

http://www.tba2.org/tba_files/TCCA/2009/sanduskyk_030409.pdf


MONIQUE D. SMITH v. STATE OF TENNESSEE

Court: TCCA

Attorneys:

J. Chase Gober, Nashville, Tennessee, for the appellant, Monique D. Smith.

Robert E. Cooper, Jr., Attorney General and Reporter; Clarence E. Lutz, Assistant Attorney General; Victor S. Johnson, District Attorney General, and Bret Gunn, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: SMITH

Petitioner, Monique D. Smith, pled guilty in the Davidson County Criminal Court to possession of .5 grams or more of cocaine for resale in exchange for a thirteen year sentence as a Range II, multiple offender. The judgment specified that the jail fees were waived and that the sentence was to run concurrently with Petitioner's sentence in another case. Petitioner subsequently sought post- conviction relief on the basis that his guilty plea was unknowingly and involuntarily entered; he was denied effective assistance of counsel; the trial court failed to fully explain the plea agreement; he was illegally seized and arrested; and his conviction was based on constitutionally insufficient evidence. The post-conviction court denied relief. Petitioner appeals, arguing that the trial court improperly denied post-conviction relief. We determine that Petitioner failed to demonstrate by clear and convincing evidence that trial counsel was ineffective or that his guilty plea was involuntary. We therefore, affirm the judgment of the post-conviction court.

http://www.tba2.org/tba_files/TCCA/2009/smithm_030409.pdf


STATE OF TENNESSEE v. BRANDON D. THOMAS

Court: TCCA

Attorneys:

L. Scott Grissom, Public Defender, McMinnville, Tennessee, for the appellant, Brandon D. Thomas.

Robert E. Cooper, Attorney General and Reporter; John H. Bledsoe, Assistant Attorney General; Lisa Zavogiannis, District Attorney General; and Thomas Miner, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge: WELLES

The Defendant, Brandon D. Thomas, was convicted by a jury of misdemeanor evading arrest. He was sentenced to serve eleven months and twenty-nine days in the Warren County Jail. In this direct appeal, the Defendant contends that the trial court erred in refusing to instruct the jury on resisting arrest as a lesser-included offense of misdemeanor evading arrest. We conclude that this contention lacks merit, and we accordingly affirm.

http://www.tba2.org/tba_files/TCCA/2009/thomasb_030409.pdf


STATE OF TENNESSEE v. MICHAEL A. VIRGA

Court: TCCA

Attorneys:

H. Marshall Judd, Allison Roberts, and Edwin G. Sadler, Cookeville, Tennessee (at trial); and F. Chris Cawood, Kingston, Tennessee (on appeal), for the appellant, Michael Virga.

Robert E. Cooper, Jr., Attorney General and Reporter; Cameron L. Hyder, Assistant Attorney General; Randall A. York, District Attorney General; Anthony J. Craighead and Beth Willis, Assistant District Attorneys General, for the appellee, State of Tennessee.

Judge: WITT

The defendant, Michael Virga, was convicted of aggravated arson for burning down a trailer home where he resided. He was also convicted of first degree felony murder for the death of Rochelle Hinrich, who died in the fire. He challenges his convictions, arguing that the trial court should have granted his motion to suppress his confession to law enforcement officers because the statements were not given freely, voluntarily, and intelligently. He also challenges the sufficiency of the convicting evidence. Discerning no error, we affirm the judgments of the trial court.

http://www.tba2.org/tba_files/TCCA/2009/virgam_030409.pdf


TODAY'S NEWS

Supreme Court Report
Legislative News
Legal News
Passages
Disciplinary Actions
TBA Member Services

Supreme Court Report
Court rejects limits on drug lawsuits
The Supreme Court forcefully rejected calls Wednesday for limiting consumer lawsuits against drug makers, upholding a $6.7 million jury award to a musician who lost her arm to gangrene following an injection. In a 6-3 decision, the court rejected the pharmaceutical company's claim that federal approval of the drug and its warning label should shield the company from lawsuits.
Read more from the AP
Asylum claim considered
The U.S. Supreme Court has kept alive the asylum case of a former prison guard who says he was forced to persecute others. The court ruled 8-1 in the case of Daniel Girmai Negusie, who helped operate a prison camp in Eritrea during a war with Ethiopia, that being coerced to participate in the persecution of others should not bar asylum under U.S. law.
Learn more in the ABA Journal
Justices to hear electronic republication case
The U.S. Supreme Court has accepted an appeal by publishers seeking to reinstate a settlement providing compensation for the electronic republication of freelance articles. The court said today it would limit its review to one issue: whether federal law restricts federal court jurisdiction in copyright infringement actions. A lower court threw out a settlement deal worth as much as $18 million because the freelance articles were not copyrighted.
Reuters reports
Legislative News
Bredesen sends 97-bill package to hill
Gov. Phil Bredesen unveiled his legislative package this week, sending 97 measures to the state legislature. The proposals include bills requiring the state Judicial Selection Commission to open its meetings to the public, requiring suspension of gun permits when owners are charged with a violent felony, and eliminating tax exemptions for family owned rental properties.
Read more in the Tennessean
Judiciary Committee acts on gun bills
The state House Judiciary Committee today approved bills allowing those with handgun permits to take weapons into state parks and wildlife management areas and deleting requirements that purchasers of firearms give a thumbprint as part of the background check process. It delayed consideration of a bill that would have allowed gun permit holders to bring handguns into establishments selling alcohol and a proposal that would have shut down public access to information on who holds handgun permits.
Learn more from the Times Free Press
Track legislation of interest to Tennessee attorneys
The TBA Action List tracks bills in the General Assembly that the TBA has a direct interest in. This means it has either initiated the legislation, taken a postiion on the bill or has a policy on the issue. The TBA Watch List is a broader list of bills of interest to the Tennessee legal community.
TBA Bill Tracking Service
Leahy pushes for truth commission
U.S. Sen. Patrick Leahy, D-VT, chair of the Senate Judiciary Committee, called today for a "Truth Commission" to investigate the Bush administration's national security policies, including search and seizure powers claimed by the former administration. The committee's top Republican, Sen. Arlen Specter of Pennsylvania, did not embrace the idea, saying the Justice Department is already investigating the Bush policies and releasing its secret memos. WTVF-NewsChannel 5 reported the story.

Legal News
Brentwood judge stepping down
Brentwood municipal court judge Thomas W. Schlater, who is known for his work with teenagers facing driving offenses, will step down from the bench this summer after 40 years of service. His replacement will be selected by the city commission. Candidates must be lawyers and be licensed to practice law in Tennessee.
Learn more about his tenure in the Tennessean
Prosecutors argue evidence strong in Obama plot
Federal prosecutors say two white supremacists accused of plotting to kill President Barack Obama and dozens of other black people were armed and dangerous when West Tennessee authorities arrested them, and that sheriff's deputies had a reliable tip the pair was planning violent crimes. The statements are intended to counter defense claims that there was little evidence to support the arrest of the two men. A court hearing is set next week on a defense petition to suppress government evidence.
The Jackson Sun has more
Passages
Services Friday for Johnson City attorney Jason Blackburn
Johnson City attorney Jason Wayne Blackburn died Tuesday at Methodist University Hospital in Memphis while awaiting a liver transplant. He was 34. A former resident of Maryville, Blackburn was a graduate of the University of Tennessee College of Law. The family will receive friends from 6 to 8 p.m. Friday, with services to follow at 8 p.m. at McCammon-Ammons-Click Funeral Home in Maryville. Family and friends will meet at 10 a.m. Saturday at Grandview Mausoleum for the entombment service.
More information is available from McCammon-Ammons-Click Funeral Home
Former Assistant DA, judge dies in Bristol
Johnson City attorney William "Bill" Mooney died last week at Wellmont Hospice House in Bristol. He was 68. A graduate of the University of Tennessee College of Law, Mooney served the state of Tennessee as an assistant district attorney for 25 years, for the counties of Washington, Carter, Johnson, Unicoi and Sullivan, and also served as the city judge of Johnson City for 14 years.
Read more about Mr. Mooney in the Johnson City Press
Disciplinary Actions
Knoxville lawyer disbarred
On March 2, Knoxville lawyer Nathanael Ellis Anderson was disbarred and ordered to pay restitution totaling $70,811.85 to former clients. The action came after the Board of Professional Responsibility received 46 complaints about Anderson from judges, attorneys and clients in a seven-month period. His misconduct included practicing law while on suspension and making false statements to courts, opposing counsel and clients.
Download the BPR release
Knoxville attorney suspended
Knoxville attorney Randy Miller was suspended from the practice of law on Feb. 24 for failing to respond to the Board of Professional Responsibility about a complaint of misconduct. The suspension will remain in effect until dissolved or modified by the Supreme Court.
Read the BPR notice
Kentucky lawyer censured
On Feb. 25, David Randall Steele, who is licensed in Tennessee but maintains an office in Kentucky, was censured by the Board of Professional Responsibility for entering into a contract with a client that prospectively limited his liability for malpractice.
Learn more from the BPR
TBA Member Services
First Tennessee is TBA's preferred provider
First Tennessee has crafted a package of discounts to meet the specific needs of Tennessee Bar Association members. Find savings on merchant credit services, checking and savings, financial planning and more
on the TBA Web site

 
 
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About this publication: Today's News is a compilation of digests of news reports of interest to Tennessee lawyers compiled by TBA staff, links to digested press releases, and occasional stories about the TBA and other activities written by the TBA staff or members. Statements or opinions herein are those of the authors and do not necessarily reflect those of the Tennessee Bar Association, its officers, board or staff.

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