Joseph Anthony Santillan, Defendant, appeals from his convictions for second degree murder, felony murder, attempted especially aggravated robbery, and attempted aggravated robbery, and effective sentence of life imprisonment plus five years for his involvement in the shooting death of a Nashville tourist in September of 2016. After the denial of a motion for new trial, Defendant appeals, raising the following issues: (1) whether the trial court erred by limiting the questioning about a witness’s criminal history; (2) whether the trial court erred by prohibiting defense counsel from questioning a witness about leniency in exchange for her testimony; (3) whether the trial court erred by prohibiting evidence of Defendant’s cooperation with law enforcement; (4) whether the trial court erred by admitting gruesome crime scene photographs into evidence; and (5) whether the evidence was sufficient to sustain the convictions. After a thorough review, we affirm the judgments of the trial court.

Following a single-vehicle accident on a road owned and controlled by the City of Shelbyville (the “City”), Tony Carrick and his wife, Linda Carrick (together, “Plaintiffs”), filed suit against the City alleging damages for personal injury, injury to property, and loss of consortium. The City moved for summary judgment on the basis that it retained its immunity under the Governmental Tort Liability Act (“GTLA”) because it had no actual or constructive notice of a defective, unsafe, or dangerous condition on the road where the accident occurred. The trial court agreed with the City and granted its motion for summary judgment. Having reviewed the record, we conclude that genuine issues of material fact exist regarding whether the City had actual or constructive notice of the condition at issue. We reverse.

COLE, Circuit Judge. To use the Federal Arbitration Act to enforce an arbitration agreement, a party must have entered an arbitration agreement. This admittedly tautological principle resolves the first part of this case. An equally fundamental principle resolves the second part: declining to exercise supplemental jurisdiction over an action with no remaining federal claims is not an abuse of discretion. We affirm.

JULIA SMITH GIBBONS, Circuit Judge. Christopher Phillips was arrested for driving on a suspended license and booked into the Lansing City Jail. Three hours later he was discovered unconscious in a pool of vomit and pronounced dead of a drug overdose. Although numerous officers were tasked with monitoring Phillips’s wellbeing, they admittedly failed to follow jail procedures designed to prevent these sorts of tragedies. For some of the officers, their negligence in monitoring Phillips insulates them from liability in this deliberate indifference action, which requires subjective knowledge and conscious disregard of a detainee’s serious medical needs. But a jury could conclude that one officer, Brian Kelley, had the requisite state of mind for liability. As to Kelley only, we reverse the district court’s grant of summary judgment. We affirm the district court’s grant of summary judgment to the remaining defendants, as well as the grant of summary judgment to all the defendants on the state law gross negligence claim because the plaintiff failed to demonstrate a triable issue on causation.

The Defendant-Appellant, James D. Duncan, pleaded guilty to possession of methamphetamine for resale and was give a suspended sentence of ten years on supervised probation. The trial court later revoked the Defendant’s probation following the issuance of a violation of probation warrant and a revocation hearing. The Defendant now argues on appeal that the trial court should have sua sponte recused itself due to comments made during the probation revocation hearing. Upon our review, we affirm the judgment of the trial court.

The petitioner, Ricardo Antonio Demling, was convicted by a jury of theft of property valued between $10,000 and $60,000, for his involvement in stealing two utility trailer vehicles (UTVs), and sentenced to fifteen years as a Range III persistent offender to be served consecutively to any unexpired sentences. He now appeals from the denial of postconviction relief claiming ineffective assistance of counsel based on the following grounds: (1) upon receipt of the State’s amended discovery response containing a statement by the petitioner and the name Christopher Brown, the alleged owner of a UTV, trial counsel’s failure to move to dismiss the charge, failure to suppress the statement by the petitioner, and failure to file a motion to continue the trial; (2) failure to interview and secure the testimony of Christopher Brown; (3) failure to file a motion based on Brady v. Maryland, 373 U.S. 83 (1963), and State v. Ferguson, 2 S.W.3d 912, 916 (Tenn. 1999), concerning the alleged destruction of a dash cam recording of the instant traffic stop; (4) failure to file a speedy trial motion to dismiss based on the sixty-seven month delay between the date of the alleged crime and the date of the arrest; and (5) failure to file a motion to dismiss based upon the sixteen month delay between the date of the arrest and the trial. Upon our review, we affirm the judgment of the post-conviction court.

This healthcare liability action was brought against a skilled nursing facility. The plaintiff sent pre-suit notice to multiple potential defendants prior to initiating the action. The plaintiff, however, failed to include as part of the pre-suit notice a HIPAA-compliant medical authorization as one of the six core elements was missing from the authorization. Following a motion to dismiss filed pursuant to Tennessee Rule of Civil Procedure 12.02(6), the Trial Court granted the motion and dismissed the action against the defendant due to noncompliance with Tennessee Code Annotated § 29-26-121 and as being untimely. The Trial Court denied the plaintiff’s request to compel discovery in this matter concerning whether the plaintiff had substantially complied with the pre-suit notice requirement. The plaintiff argues on appeal that the Trial Court erred by not treating the defendant’s motion as a motion for summary judgment and by preventing the plaintiff from conducting discovery regarding the plaintiff’s compliance with Section 29-26-121, as well as the resulting prejudice to the defendant. Discerning no error, we affirm the Trial Court’s judgment in all respects.

This case involves a petition to modify a permanent parenting plan for two minor children. The children’s father filed the petition, alleging that there had been a material change of circumstances since the plan was entered and that, as a result, he should be designated as the children’s primary residential parent. The children’s mother denied that there had been a material change of circumstances and filed a counter-petition to modify the father’s child support obligation. After a hearing on the parties’ petitions, the trial court found that there had not been a material change of circumstances to justify modifying the plan. However, the trial court modified several aspects of the plan. The trial court further found that the father was voluntarily underemployed and that his child support obligation should be modified accordingly. Father appealed. We affirm the trial court in part, reverse in part, vacate in part, and remand.

The Juvenile Court for Cocke County (the “trial court”) entered an order terminating the parental rights of Jose G.L. as to his minor child, Ahleigha C. (the “Child”). The trial court found, by clear and convincing evidence, that Father’s rights should be terminated for abandonment and failure to manifest an ability and willingness to assume custody of the Child. Father appeals. Because the Tennessee Department of Children’s Services failed to prove either ground for termination by clear and convincing evidence, we reverse.

ALICE M. BATCHELDER, Circuit Judge. Jon Hall, a Tennessee death row inmate, has appealed the district court’s denial of his petition for a writ of habeas corpus, filed under 28 U.S.C. § 2254. In this appeal, Hall sought and we granted a certificate of appealability (“COA”) on claims that: (1) the state prosecutor withheld exculpatory evidence of a state witness’s mental illness; (2) Hall’s trial counsel was ineffective for failing to challenge Hall’s competency to stand trial; and (3) Hall’s trial counsel was ineffective for failing to present certain family- and social-history evidence. Finding that Hall cannot prevail on any of these claims, we AFFIRM.