Jeffery Siler, Defendant, appeals the trial court’s summary dismissal of his Tennessee Rule of Criminal Procedure 36 motion to correct a clerical error in the trial court’s order revoking Defendant’s probation. Defendant claims that the revocation order erroneously failed to award 622 days’ jail credit for the time Defendant served on a concurrent federal sentence while his state court sentence was suspended and Defendant was on unsupervised probation. Defendant’s probationary period ran from the date of his state court convictions until the date the probation revocation warrant was issued. This probationary period encompassed the 622 days Defendant was incarcerated on the concurrent federal sentence. Because Defendant’s probation was revoked before his probationary period expired, Defendant was not entitled to credit upon reinstatement of the original state court sentence. State v. Hunter, 1 S.W.3d 643, 644 (Tenn. 1999). Therefore, there is no clerical error in the revocation order. We affirm the trial court’s summary denial of the Rule 36 motion.

Plaintiff, a former pastor at a church in Chattanooga, brought suit against the church, church elders, and another pastor at the church, alleging that various torts were committed against him. Following a series of motions by the defendants that sought the dismissal of plaintiff’s claims, the trial court ultimately dismissed all legal theories that were asserted in the case. Among other bases for the dismissal, the trial court held that a number of plaintiff’s claims were barred by the ecclesiastical abstention doctrine. Discerning no error in the trial court’s decision to dismiss plaintiff’s claims, we affirm its judgment.

Week of October 12, 2020 - October 16, 2020

KAREN NELSON MOORE, Circuit Judge. On appeal from his drug-trafficking convictions, Craig Snoddy challenges the district court’s denial of his motion to suppress the evidence resulting from an inventory search of his car. Past midnight on a dark highway, Tennessee Highway Patrol Officer Adam Malone stopped Snoddy for speeding and arrested him on outstanding warrants, including for drug crimes. As Snoddy was the sole occupant of the car, Trooper Malone called for a tow truck to have Snoddy’s car impounded. Trooper Malone was required by state policy to conduct an inventory search of Snoddy’s car prior to towing. Snoddy claims that the inventory search in reality was a pretext for an investigative search for drugs, in violation of the Fourth Amendment. Because the district court did not clearly err in finding no such pretext, we AFFIRM the district court’s denial of Snoddy’s motion to suppress.

CLAY, Circuit Judge. The latest appeal in this multi-district litigation (“MDL”) relating to the opioid crisis centers on the district court’s order certifying a “negotiation class” under Federal Rule of Civil Procedure 23. The court has certified a class of all cities and counties throughout the United States for purposes of negotiating a settlement between class members and opioid manufacturers, distributors, and pharmacies. Appellants, objecting opioid distributors and retail pharmacies (“Defendants”), as well as six objecting Ohio cities, appeal the district court’s order certifying this negotiation class. Appellees, putative representatives of the negotiation class (“Plaintiffs”), request us to approve this novel form of class action. For the reasons provided below, we decline to do so, and therefore REVERSE the district court’s order.

RALPH B. GUY, JR., Circuit Judge. Jeremy Cruz was sentenced to 188 months of imprisonment after he pleaded guilty to three offenses: transporting a minor with intent to engage in sexual activity; receiving child pornography; and transporting child pornography. Cruz had maintained a two-year online relationship with the victim before he picked her up in California, traveled across the country, and had sex with her on multiple occasions. Cruz appeals his sentence, arguing the district court erred in imposing a two-level offense enhancement on Count 1 for “unduly influenc[ing] a minor to engage in prohibited sexual conduct.” USSG § 2G1.3(b)(2)(B).

It was not an abuse of discretion for the sentencing court to impose the enhancement. But even if that were not the case, any claimed error is harmless. The application of the enhancement did not alter Cruz’s Sentencing Guidelines range or resulting sentence because Cruz was sentenced to a term of imprisonment at the top of the Guidelines range established by Counts 2 and 3—which did not include the undue-influence enhancement. Accordingly, Cruz’s sentence is AFFIRMED.

MURPHY, Circuit Judge. After learning of an outstanding arrest warrant for Tyslen Baker, a police officer entered his residence to arrest him and spotted drugs and a firearm in a back room. Baker moved to suppress this incriminating evidence on the ground that the police had violated the Fourth Amendment in two ways. Baker first argued that the officer who executed the arrest warrant subjected him to an “unreasonable” “seizure” by entering that back room without his consent. Baker next argued that the separate officer who requested the arrest warrant from a state judge relied on an affidavit lacking “probable cause” that Baker had committed a crime.

We hold that the district court correctly denied Baker’s motion to suppress this evidence. The officer who arrested Baker acted reasonably in monitoring his movements during the arrest. See Washington v. Chrisman, 455 U.S. 1, 7 (1982). And the affidavit supporting the warrant contained enough of a connection between Baker and a crime that the officers could reasonably rely on the state judge’s probable-cause finding. See United States v. Leon, 468 U.S. 897, 922 (1984). Whether or not probable cause existed, therefore, the warrant should not trigger the exclusionary rule. Id. And while Leon’s exception to the exclusionary rule arose in the context of a search warrant allegedly lacking probable cause, we think the Court would extend its basic rules to arrest warrants too. Cf. Herring v. United States, 555 U.S. 135, 137 (2009). We thus affirm.

Santos M. Martinez-Aleman, Petitioner, appeals from the denial of habeas corpus relief from his guilty plea to two counts of sexual battery and resulting twelve-year sentence. After a review, we affirm the denial of habeas corpus relief.

The petitioner, Shawn Gibson Delosh, appeals the denial of his post-conviction petition arguing the post-conviction court erred in finding he received effective assistance of counsel at trial and on appeal. Following our review, we affirm the post-conviction court’s denial of the petition.

The Petitioner, Ryan D. Buford, appeals the denial of his petition for post-conviction relief, asserting that he received ineffective assistance of trial and appellate counsel. After review, we affirm the denial of the petition.