A local government cited a property owner for operating his property as a short-term rental without a permit. A general sessions court found the property owner violated the shortterm rental ordinance and enjoined him from committing further violations. The government later brought two criminal contempt actions against the property owner, claiming that he violated the court’s injunction by continuing to run a short-term rental without a permit. The first time, the property owner acknowledged his violations, and the general sessions court entered an agreed order. The second time, the court found the property owner guilty of contempt after a hearing. The property owner appealed that finding to the circuit court. The circuit court found that the property owner was in contempt of the general sessions court’s order on eighteen occasions. Finding no error, we affirm.

In post-divorce proceedings, a former husband petitioned to reduce or terminate his alimony in futuro payments to his former wife. The trial court denied the former husband’s request, ruling that he failed to show that a substantial and material change of circumstances had occurred since the alimony was awarded. The former husband appealed, and we affirm the trial court’s judgment.

Appellant/Mother appeals the trial court’s termination of her parental rights to the minor child on the grounds of: (1) abandonment by failure to visit, Tenn. Code Ann. §§ 36-1- 113(g)(1), 36-1-102(1)(A)(i); (2) abandonment by failure to provide a suitable home, Tenn. Code Ann. §§ 36-1-113(g)(1), 36-1-102(A)(ii); (3) substantial noncompliance with the requirements of the permanency plan, Tenn. Code Ann. § 36-1-113(g)(2); and (4) persistence of the conditions that led to the child’s removal, Tenn. Code Ann. § 36-1- 113(g)(3). Appellant also appeals the trial court’s finding that termination of her parental rights is in the child’s best interest. Discerning no error, we affirm.

PER CURIAM. Federal law makes it illegal to employ undocumented aliens, but Tennessee’s workers’ compensation law still protects them. So if a Tennessee company fires an undocumented employee for filing a workers’ compensation claim, the employee can sue for damages. Because of the federal law, the company cannot be required to pay lost wages that the alien was not allowed to earn. But it’s still on the hook for wages the employee could have lawfully received, as well as for other damages unrelated to the employee’s immigration status.

Ricardo Torres obtained authorization to work in the United States several months after he was fired for filing a workers’ compensation claim. The district court appropriately awarded him backpay for the period in which he was authorized to work, plus non-economic and punitive damages. But the court mistakenly included two extra months’ wages in the backpay calculation. We reduce the damage award accordingly and affirm.

CLAY, Circuit Judge. Plaintiff Johnny Strickland appeals, in part, the district court’s order granting summary judgment in favor of his employer, the City of Detroit (“the City”), as well as Detroit Police Chief James Craig, Commander Mark Bliss, Sergeant Rodney Ballinger, Officer Steven Murdock, Officer Casey Schimeck, and Sergeant Deanna Wilson. On appeal, Plaintiff claims that the City maintained a hostile work environment, in violation of Title VII of the Civil Rights Acts of 1964, 42 U.S.C. § 2000e et seq., and retaliated against him for reporting racial discrimination, also in violation of Title VII, specifically § 2000e-3(a). He also asserts that Officer Schimeck is not entitled to qualified immunity on his excessive force claim brought pursuant to § 1983. For the reasons that follow, we affirm in part and reverse in part the district court’s grant of summary judgment.

JOHN K. BUSH, Circuit Judge. As judges, we assume that Congress says what it means and means what it says. That is why statutory interpretation begins with the text. FNU Tanzin v. Tanzir, 141 S. Ct. 486, 489 (2020). When Congress reduced the scope of 18 U.S.C. § 924(c)’s extreme penalties, it said how the amendments apply to past crimes. They apply for a defendant on whom “a sentence for the offense has not been imposed as of” December 21, 2018. First Step Act § 403(b) (codified at 18 U.S.C. § 924 notes). As of that day, a sentence had been imposed on Kenneth Jackson, Jr. That we later vacated his first sentence does not alter Jackson’s status on the day the First Step Act became law. For that reason, we again vacate his sentence and remand for resentencing.

CHAD A. READLER, Circuit Judge. Jankie Jackson and Peter Combs pleaded guilty to participating in a cocaine distribution ring. Both defendants received elevated sentences, Jackson due to his role as a leader in the drug-distribution conspiracy, and Combs due to his alleged career-offender status. Seeing no error in Jackson’s sentence, we affirm that aspect of the district court’s judgment. Due to intervening circuit precedent, however, we reverse the district court’s career-offender finding for Combs and remand for resentencing.

A mother and father of three children were divorced in 2018, and both parties filed petitions to modify the permanent parenting plan later that year. Both parties also asked the trial court to hold the other party in contempt for violating the parenting plan and engaging in other objectionable conduct. The trial court found the father guilty of two counts of contempt and the mother guilty of three counts of contempt, and it ordered them to spend two days in jail for each count. The court granted the husband’s petition to modify the parenting plan and changed the designation of the primary residential parent from the mother to the father. The mother appeals, and we affirm the trial court’s judgment in all respects.

The Petitioner, Stephen Gerard Smith, was convicted by a jury of aggravated assault, attempted aggravated assault, and three counts of domestic assault for offenses committed against his wife, and he received an effective twenty-five-year sentence. He sought and was denied post-conviction relief based on numerous allegations of ineffective assistance of counsel. On appeal, he alleges that he received ineffective assistance when trial counsel: (1) gave deficient advice regarding a plea offer; (2) failed to challenge a prospective juror; (3) argued in closing argument that the Petitioner was guilty of the misdemeanor offenses; (4) failed to object to testimony referring to the Petitioner’s prior incarceration; (5) failed to object to the prosecutor’s comment on the victim’s credibility; (6) failed to call witnesses; and (7) failed to interview witnesses. Because we conclude that the Petitioner has not established either deficiency or prejudice for each claim, we affirm the denial of post-conviction relief.

A jury convicted the Defendant, Marvin Maurice DeBerry, of driving after having been declared a motor vehicle habitual offender (“MVHO”) and of three misdemeanor offenses not presented for appellate review. After his conviction but prior to his sentencing, an amendment to the statute that was the basis of his MVHO conviction went into effect, so that the Defendant’s conduct was no longer criminalized and, concomitantly, triggered no penalty. The trial court, after initially sentencing the Defendant to serve five years, modified the Defendant’s judgment to reflect that he was to be subjected to no penalty. On appeal, we are called to determine whether the Defendant may benefit from the savings statute in Tennessee Code Annotated section 39- 11-112. We hold that the savings statute applies because Legislature’s act of removing punishment for the offense constitutes a lesser penalty. Accordingly, we affirm the trial court’s judgment reducing the Defendant’s sentence.