TBA's Indigent Representation Primer series recently featured two articles that provide basics about Tennessee's system for appointed counsel as well as context for discussions about increased resources for indigent representation. The initial primer article introduces the basics of our state's system and the situations that require counsel be appointed for individuals unable to afford representation. The second primer article highlights background and data about Tennessee's Indigent Representation Program, including how courts determine and assign counsel for indigent defendants and vulnerable individuals. Both items include information about the General Assembly's 2024 increased funding for indigent representation — a step in the right direction, but still leaving a significant gap to fill.

CLAY, Circuit Judge. This 42 U.S.C. § 1983 action arises from a criminal investigation of Plaintiffs for a fire that occurred at their restaurant in Westland, Michigan. In Case No. 19-1882, Defendants John Adams and Michael Reddy Jr. appeal the district court’s denial of their motion to dismiss Plaintiffs’ civil conspiracy claim on qualified immunity grounds. In Case No. 19-1870, Defendant Michael Reddy Sr. appeals the district court’s denial of his motion to dismiss Plaintiffs’ civil conspiracy claim for failure to state a claim on which relief can be granted. And in Case No. 19-1857, Defendant Richard Sanchez appeals the district court’s denial of his motion to dismiss Plaintiffs’ Fourth Amendment unlawful search and seizure claim on qualified immunity grounds. For the reasons that follow, we dismiss Reddy Sr.’s appeal for lack of jurisdiction and affirm the district court’s order with respect to the other Defendants.

The Defendant, Yancey Lee Williams II, was convicted by a jury of first degree premeditated murder, for which he received a sentence of life imprisonment. On appeal, the Defendant argues that (1) there was insufficient evidence to support his conviction, specifically, challenging the element of premeditation; (2) the trial court erred by finding that he was engaged in unlawful activity and thereby omitting the “no duty to retreat” language from the self-defense instruction; (3) the prosecutor made improper and inflammatory comments regarding religion and race during closing arguments; and (4) plain error occurred when the State failed to provide pretrial documentation of a witness’s statement to law enforcement despite an order being in place directing such disclosure. After a thorough review of the record, we affirm the judgment of the trial court.

In Tennessee, is there ever a time when a prosecutor would not be allowed to dismiss a case after indictment? Politics aside, the controversy over the United States Department of Justice’s motion to dismiss the case against Michael Flynn presents important issues regarding the scope of authority between prosecutors and courts.

The Tennessee Supreme Court continued its longstanding SCALES (Supreme Court Advancing Legal Education for Students) program this year, engaging with rising high school seniors at both Volunteer Girls State and Volunteer Boys State. Justices Sarah Campbell and Mary Wagner took part in the 80th American Legion Auxiliary (ALA) Volunteer Girls State (VGS) session at Lipscomb University, where they held a candid fireside chat that ALA VGS Chair Jenise Gordon said gives the roughly 500 attendees "permission to be ambitious and uncertain at the same time." Meanwhile, Chief Justice Jeff Bivins and colleagues visited the 87th Volunteer Boys State at Tennessee Tech University, where 400 young men observed oral arguments and interacted with justices off the bench. Since 1995, SCALES has brought the state's judiciary directly to these mock-government programs — which together have educated tens of thousands of Tennessee students since the 1940s — with organizers crediting the experience for inspiring many delegates to pursue law careers. Read more in a press release from the Administrative Office of the Courts.

Nashville Mayor Freddie O'Connell has nominated newly retired Metro Legal Director Wally Dietz to the locally appointed Metro Nashville Airport Authority, a pick that needs Metro Council approval at its July 21 meeting and would run through 2031. The Nashville Post reports that the nomination comes as a new state law took effect July 1 replacing the local board with a state-appointed one. O'Connell has declined to name anyone to that panel, and the original Metro-appointed board continues operating. Metro Nashville is suing over the takeover, arguing the Federal Aviation Administration (FAA) cannot recognize the new state board without Metro's consent. The state-appointed board recently voted to withdraw from that lawsuit. A preliminary ruling is expected by month's end.

KETHLEDGE, Circuit Judge. Melvin Steger alleges that—without warning, while he stood on his front porch, albeit after shouting an obscenity—Officer Steven Willis slammed him to the ground and punched him twice before handcuffing him. The district court held, among other things, that those alleged facts would amount to a violation of Steger’s clearly established rights under the Fourth Amendment. We agree and affirm.

THAPAR, Circuit Judge. Over fifteen years ago, Congress enacted the Affordable Care Act, intending to dramatically restructure the American health-insurance market. But some of its provisions appear to have gone unimplemented and unenforced. In 2024, the American Association of Nurse Anesthesiology sued the Secretary and Department of Health and Human Services to compel them to enforce one such provision that prohibits insurers from discriminating against healthcare providers. The Association alleged that private insurers were violating the Act by paying nurse anesthetists less than physician anesthesiologists who provide the same services. And it sought extraordinary relief: a judicial order requiring an executive- branch agency to take unspecified enforcement actions that the Association speculated would remedy the alleged discrimination. Because the Association lacks standing, we affirm the district court’s dismissal of its claims.

A Knox County jury convicted the Defendant, Charles Raymond Locke, Jr., of second degree murder, and the trial court imposed a twenty-five-year sentence. The Defendant appeals, asserting that the trial court erred when it denied his motion to suppress his statement to the police and that the trial court abused its discretion when it sentenced him to serve twenty-five years in prison. After a thorough review of the record, we affirm the trial court’s judgment.