The pro se petitioner, Jesse L. Dabbs, appeals the Davidson County Criminal Court’s summary dismissal of his motion to correct an illegal sentence, filed pursuant to Tennessee Rule of Criminal Procedure 36.1. Discerning no error, we affirm.

This is the second appeal in this divorce case. In Ellis v. Ellis, No. W2017-02287-COAR3- CV, 2019 WL 410704 (Tenn. Ct. App. Jan. 31, 2019), we vacated the trial court’s award of alimony in futuro to Wife and its award of alimony in solido for Wife’s attorney’s fees. Contrary to our mandate, on remand, the trial court failed to consider Wife’s relative earning capacity in relation to the award of alimony in futuro. Although the trial court affirmed its previous award of alimony in solido, it failed to consider payments Wife made from pendente lite support she received from Husband. Accordingly, we modify the trial court’s award of alimony in futuro to reflect Wife’s earning capacity, and we modify the award of alimony in solido to reflect payments made from pendente lite support.

GRIFFIN, Circuit Judge. The principal issue in this appeal is whether the registration and notification obligations set forth in the federal Sex Offender Registration and Notification Act (SORNA) apply to sex offenders who are convicted under state law but are not subject to that state’s sex offender registration and notification requirements. Our sister circuits have answered the question in the affirmative and so have we in an unpublished opinion, United States v. Paul, 718 F. App’x 360, 363–64 (6th Cir. 2017). Today, based upon the text of the statute, we follow those decisions and hold that a sex offender’s obligations under SORNA are independent of any duties under state law.

Plaintiff M.S. Willman also argues that SORNA is unconstitutional for several reasons. We conclude that none of these arguments have merit and therefore affirm the judgment of the district court dismissing plaintiff’s complaint.

Shawn Williams, a federal prisoner proceeding with counsel, appeals the district court’s order denying his motion for a sentence reduction under the First Step Act of 2018. The parties have waived oral argument, and this panel unanimously agrees that oral argument is not needed. See Fed. R. App. P. 34(a).

We vacate the district court’s order and remand the case for further proceedings consistent with this opinion.

RONALD LEE GILMAN, Circuit Judge.In June 2018, Kenneth Lowe was fired from his job at Walbro LLC. Lowe was 60 years old at the time and had worked at Walbro for more than four decades. He responded by filing this lawsuit against Walbro, alleging that the company had violated Michigan’s Elliott-Larsen Civil Rights Act (ELCRA), Mich. Comp. Laws § 37.2101 et seq., by discharging him because of his age. The district court granted summary judgment in favor of Walbro. For the reasons set forth below, we REVERSE the judgment of the district court and REMAND the case for further proceedings consistent with this Opinion.

The defendant, Jessica Cox, appeals her Knox County Criminal Court jury convictions of aggravated child abuse and reckless endangerment, arguing that the trial court erred by excluding evidence of an expert witness, that the trial court erred by excluding certain testimony and preventing her from mounting a defense, and that the evidence was insufficient to support certain convictions. Discerning no error, we affirm.

This appeal concerns a legal dispute between a landlord and a commercial tenant. The trial court found that the landlord, a recent purchaser of the commercial property, had breached the pre-existing lease. We affirm the judgment of the trial court.

The issue presented is whether a quitclaim deed should be equitably reformed when reformation would benefit parties with constructive notice of a title defect and harm the rights of creditors with recorded judgment liens. A husband and wife quitclaimed parcels of real property to limited partnerships. The wife was omitted as a grantor on one of the quitclaim deeds even though she and her husband owned the property as tenants by the entirety. Two banks obtained judgments against the husband and wife and recorded the judgments. The property was later sold, and the purchasers and their lender discovered that the property was subject to the wife’s retained ownership interest and the banks’ recorded judgment liens. To remedy the error, the husband and wife signed a quitclaim deed of correction, referencing the wife’s omission as a grantor on the previous quitclaim deed. The purchasers and their lender then filed this declaratory judgment action asking the trial court to hold, based on mutual mistake, that the corrected quitclaim deed reformed the original quitclaim deed, vested ownership in the limited partnership, divested the wife’s interest, and removed the banks’ judgment liens. The trial court denied reformation, finding that there was no mutual mistake by the husband and the limited partnership who signed the original quitclaim deed. The Court of Appeals affirmed. After considering the equities of the parties, we decline to grant reformation of the quitclaim deed because doing so would deprive the banks of their recorded judgment liens and benefit the purchasers and their lender who acquired the property with constructive notice of the wife’s remaining interest in the property and the banks’ recorded judgment liens. Thus, we need not decide whether reformation is an available remedy to correct a quitclaim deed by adding an omitted grantor. We affirm the judgments of the trial court and the Court of Appeals, based on different reasoning.

THAPAR, Circuit Judge. By signing on the dotted line, public employees accept the government as their employer. In Ohio, the law requires them to also accept a union as their exclusive bargaining representative. It’s a take-it-or-leave-it system—either agree to exclusive representation, which is codified in state law, or find a different job. This take-it-or-leave-it system is in direct conflict with the principles enunciated in Janus v. AFSCME, 138 S. Ct. 2448 (2018). But when the Supreme Court decided Janus, it left on the books Minnesota State Board for Community Colleges v. Knight, 465 U.S. 271 (1984). And because Knight directly controls the outcome of this case, we affirm the district court’s decision upholding the challenged Ohio law.

ALICE M. BATCHELDER, Circuit Judge. A Kentucky prisoner, sentenced to death, appeals the denial of his 28 U.S.C. § 2254 petition for a writ of habeas corpus. We AFFIRM.