This case concerns an alleged contract for the sale of real property. Although a prior written offer regarding the property expired pursuant to its stated terms when it was not timely accepted, the trial court held that there was an oral agreement to extend the expiration date for acceptance and concluded that the Statute of Frauds did not serve as an impediment to enforcement of the parties’ alleged contract when the plaintiffs, the appellees herein, filed suit to enforce it. The trial court also concluded that no damages should be awarded under former Tennessee Code Annotated section 66-21-108 to the defendants, who had asserted a slander of title claim in the trial court. The defendants now appeal, challenging both the trial court’s contract law analysis and its decision to not award them statutory damages. Although we reverse the trial court’s judgment with respect to the plaintiffs’ breach of contract claim, we affirm its refusal to award the defendants statutory damages for the reasons stated herein.

This appeal involves a reimbursement limitation that TennCare imposed on “non- emergent” medical services provided by emergency department physicians. TennCare informed its managed care organizations of the reimbursement limitation via email without engaging in rule-making procedures outlined in the Uniform Administrative Procedures Act (“UAPA”). The trial court concluded the reimbursement limitation was a “rule” subject to the rule-making requirements of the UAPA and invalidated the reimbursement limitation. We hold that the reimbursement limitation falls within the internal management exception of the 2009 version of the UAPA and was therefore not subject to the UAPA’s rule-making requirements. The ruling of the trial court is reversed.

Question 1: May a private employer require its employees to be vaccinated against COVID-19 as a condition of employment?

Opinion 1: Tennessee law does not prohibit private employers from requiring their employees to be vaccinated against COVID-19 as a condition of employment. But—depending on the particular facts and circumstances in any given private employment situation—federal law, as well as collective bargaining agreements and other employment contractual obligations, may preclude a private employer from requiring its employees to be vaccinated against COVID-19, subject to appropriate exceptions, such as exceptions for medical reasons.

CHAD A. READLER, Circuit Judge. Plaintiffs believe they have been exposed to radioactive material released by a nuclear plant in Ohio. In an attempt to recover for harms that exposure allegedly caused, they asserted state law claims in state court against entities involved in the plant’s operations. The entities in turn removed the action to federal court and then argued that the Price-Anderson Act, which governs “any public liability action arising out of or resulting from a nuclear incident,” 42 U.S.C. § 2210(n)(2), preempts plaintiffs’ claims. The district court agreed and, because plaintiffs disavowed any theory of recovery under the Act, dismissed the case. We now affirm.

Petitioner, Millard Ellis Spurgeon, appeals the denial of post-conviction relief from his 2015 Sevier County convictions for burglary, theft of property valued at $1,000 or more, vandalism of property valued at $1,000 or more, and possession of burglary tools, for which he received an effective sixteen-year sentence. Petitioner argues that he was denied the effective assistance of counsel at trial. After a thorough review of the record and applicable law, we affirm the judgment of the post-conviction court.

Jabari Reynolds, Petitioner, was convicted of one count of first degree premeditated murder and was sentenced to life imprisonment. This court affirmed his conviction on direct appeal. State v. Jabari Reynolds, No. E2015-00499-CCA-R3-CD, 2017 WL 936521 (Tenn. Crim. App. Mar. 9, 2017), perm. app. denied (Tenn. Aug. 16, 2017). Petitioner filed a post-conviction petition alleging that trial counsel was ineffective for failing to focus solely on a theory of voluntary manslaughter. The post-conviction court denied his petition, and Petitioner now appeals. Following a thorough review, we affirm the judgment of the post-conviction court.

This termination of parental rights case focuses on Elijah H. (“the Child”), the minor child of Amanda H. (“Mother”) and Kevin W. (“Father”). In March 2019, the Tennessee Department of Children’s Services (“DCS”) filed a petition to terminate the parental rights of Mother and Father in the Wilson County Juvenile Court (“trial court”). The Child had previously been removed from Mother’s custody after he was born exposed to drugs. Father was incarcerated prior to the Child’s birth and has remained so continuously since that time, awaiting trial for pending criminal charges, including first degree murder. During a bench trial, Mother voluntarily surrendered her parental rights to the Child. At the conclusion of the bench trial, the trial court terminated Father’s parental rights to the Child, finding by clear and convincing evidence that Father had abandoned the Child by exhibiting wanton disregard for the Child’s welfare prior to Father’s incarceration and that Father had failed to manifest an ability and willingness to assume legal and physical custody of or financial responsibility for the Child. The trial court further found by clear and convincing evidence that it was in the Child’s best interest to terminate Father’s parental rights. Father has appealed. Having determined that DCS presented insufficient evidence that Father knew of the Child’s existence at the time of his criminal behavior, we reverse the trial court’s finding that Father abandoned the Child by exhibiting wanton disregard for the Child’s welfare. We affirm the trial court’s judgment in all other respects, including the termination of Father’s parental rights.

This appeal concerns the administration of a husband and wife’s intestate estates, consisting of several tracts of real property that the husband and wife owned as tenants by the entirety. They were both found deceased in their home several days after they had died. The wife’s heir at law, her brother, filed a petition seeking a declaration that the husband died first, that the wife, as the survivor, owned the real property at her death, and it passed to her heir at law. The husband’s heirs at law responded to the petition, contending the evidence was not sufficient to prove that the couple died in any order other than simultaneously. The only witness at the trial was the medical examiner who conducted the autopsies. He testified that it was more probable than not that the husband died first based on the causes of death and medical histories of the spouses. After considering the expert witness testimony, the trial court concluded that the evidence was not sufficient to prove that the husband and wife died otherwise than simultaneously. This appeal followed. Having determined that the trial court was not bound by the medical examiner’s speculative opinion as to who died first, we affirm the trial court’s decision.

HELENE N. WHITE, Circuit Judge [Except as to Section III.D.]. For nine years, Defendants-Appellants Radu Miclaus and Bogdan Nicolescu ran a sophisticated, multimillion- dollar cyber-fraud ring out of Romania. They were extradited to the United States, and a federal jury in Ohio convicted them of wire fraud, conspiracy to commit wire fraud, conspiracy to commit computer fraud, aggravated identity theft, conspiracy to commit money laundering, and conspiracy to traffic in counterfeit service marks. The district court sentenced them to eighteen and twenty years’ imprisonment, respectively. On appeal, they raise several challenges to their convictions and sentences. We AFFIRM their convictions, VACATE their sentences, and REMAND for resentencing.

The defendant, Jacobe Lamone Snipes, appeals his Madison County Circuit Court jury convictions of attempted first degree murder, aggravated assault, employing a firearm during the commission of a dangerous felony, and two counts of gang enhancement, arguing that the trial court erred by admitting certain evidence and that the evidence was insufficient to support his convictions. Discerning no error, we affirm.