This case involves claims against the State of Tennessee asserted by a husband and wife. The claimant husband suffered injuries when his car collided with a Tennessee state vehicle parked in the roadway. He gave written notice of his claim to the Tennessee Division of Claims and Risk Management. The Division did not resolve it, so the Division transferred the claim to the Tennessee Claims Commission. The husband and wife then filed a complaint with the Claims Commission. The complaint contained a loss of consortium claim by the wife that was not in the written notice the husband gave to the Division of Claims and Risk Management. The Claims Commission complaint was filed within the applicable one-year statute of limitations. The Claims Commission granted the State’s motion to dismiss the wife’s loss of consortium claim as time-barred because she did not give the Division of Claims and Risk Management written notice of her claim within the limitations period. The Court of Appeals affirmed. The claimants appeal, relying on the holding in Hunter v. State, No. 01-A-01-9210-BC00425, 1993 WL 133240 (Tenn. Ct. App. Apr. 28, 1993), that a complaint filed with the Claims Commission within the statute of limitations fulfills the requirement in Tennessee Code Annotated § 9-8-402(a)(1) that claimants give timely written notice of their claim against the State to the Division of Claims and Risk Management. We reject this argument, overrule Hunter v. State, and affirm the Claims Commission’s dismissal of the wife’s claim for loss of consortium.

LARSEN, Circuit Judge. Miguel Angel Guzman-Torralva was ordered removed from the country after he missed his hearing in immigration court. Now he seeks to reopen the proceedings, claiming that the bad advice of his lawyer should excuse his absence. But Guzman-Torralva hasn’t met the requirements for reopening.

Under Matter of Lozada, a motion to reopen based on ineffective assistance of counsel must state whether the alien filed a formal bar complaint against his lawyer. 19 I. & N. Dec. 637, 639 (BIA 1988). If no complaint was filed, the motion must explain why not. Id. Guzman-Torralva didn’t file a bar complaint, so the question on appeal is whether his explanation is adequate. Because we think Lozada requires more than a simple statement that the alien is “not interested in filing a formal complaint,” we DENY the petition for review.

The court received a petition for rehearing en banc. The original panel has reviewed the petition for rehearing and concludes that the issues raised in the petition were fully considered upon the original submission and decision of the case. The petition then was circulated to the full court. No judge has requested a vote on the suggestion for rehearing en banc.

Therefore, the petition is denied.

An employee sought a reasonable accommodation from her employer when she began experiencing increased difficulties with her debilitating rheumatoid arthritis. The employer was unable to provide a reasonable accommodation and, after concluding that the employee’s disability rendered her physically unable to perform the essential functions of her job, the employer removed the employee from her position and placed her on paid sick leave. The employee then resigned and sued the employer for discriminatory discharge under the Tennessee Disability Act. The trial court granted summary judgment to the employer after determining that the employee was not qualified for the position and that the employee did not suffer an adverse employment action due to her voluntary resignation. Finding no error, we affirm.

The Defendant, Timothy Prink, appeals the trial court’s summary denial of his motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1 in which he challenged his fifteen-year sentence resulting from his attempted first degree murder conviction and his four life sentences resulting from four first degree murder convictions. After review, we affirm the trial court’s judgment.

The Defendant, Bradley Dwight Bowen, appeals from the Montgomery County Circuit Court’s revocation of his effective nine-year split confinement sentence for convictions for child neglect and possession of methamphetamine. He contends that the trial court abused its discretion in ordering him to serve his sentence. We affirm the judgment of the trial court.

This appeal involves the interpretation of a partnership agreement for the purpose of determining the respective ownership percentages of the partners. After our review of the partnership agreement, we affirm the ruling of the trial court.

In this compensation appeal, the employee challenges the jurisdiction of the trial court, which dismissed his case with prejudice when he failed to appear for a scheduled trial. The employee did not attend the trial despite having been given notice of the date and time of the hearing. On appeal, the employee failed to file a brief or identify any appealable issues. We affirm the trial court’s decision dismissing the employee’s case with prejudice and certify the trial court’s order as final.

MURPHY, Circuit Judge. Ryan Estes, a dentist, conducts his dental practice through a professional services corporation named Ryan P. Estes, D.M.D., M.S., P.S.C. This corporation, which we will call “Estes,” operates two dental offices in Kentucky. In response to the COVID-19 pandemic, Kentucky temporarily barred healthcare corporations like Estes from providing nonemergency care. Estes lost substantial income as a result. The company sought to recover this money under a property insurance policy it had purchased from Cincinnati Insurance Company. The policy required Cincinnati Insurance to pay Estes for lost business income that results from a “direct” “physical loss” to its dental offices. Policy, R.23-4, PageID 763, 783. This appeal requires us to consider whether the COVID-19 pandemic or the Kentucky shutdown orders caused such a physical loss to Estes’s offices so as to allow it to recover its lost income. We and other circuit courts have uniformly interpreted this “physical loss” language not to cover similar pandemic-related claims under the laws of many other states. Because we believe Kentucky’s highest court would agree with these decisions, we affirm the dismissal of Estes’s complaint.

The Defendant, Vincent Williams, was convicted by a jury of attempted first-degree murder, employing a firearm during the commission of a dangerous felony, and aggravated assault, for which he received an effective forty-year sentence. On appeal, the Defendant argues that the trial court committed plain error when it prevented him from introducing evidence of the victim’s bias and that the evidence was insufficient to establish his identity as the perpetrator. Following our review, we affirm the judgments of the trial court.