The Petitioner, Larry Lee Johnson, appeals from the Shelby County Criminal Court’s summary dismissal of his petition for writ of error coram nobis, wherein he claimed that first coram nobis counsel refused to amend the original coram nobis petition after discovery of two witnesses’ statements that might have led to a different result had they been available at trial. The Petitioner contends that the coram nobis court erred by summarily dismissing his petition as having been untimely filed and for failing to state a cognizable claim for relief. Following our review, we affirm the judgment of the coram nobis court.

COLE, Circuit Judge. Martin Osborn pleaded guilty to threatening to assault Congressman Henry Johnson in violation of 18 U.S.C. § 115(a)(1)(B), (b)(4), and (c)(4). At sentencing, the district court refused to apply a four-level reduction under U.S.S.G. § 2A6.1(b)(6) because it concluded that his offense did not “evidenc[e] little or no deliberation.” In doing so, the court relied on prior threats Osborn made against other government officials that are not “relevant conduct” under U.S.S.G. § 1B1.3. But while the relevant conduct provision prohibits the district court from altering the base offense level using certain uncharged conduct, it does not alter its traditional fact-finding role. And the district court here did not clearly err in concluding that Osborn’s offense evidenced more than “little or no deliberation.” We therefore affirm the sentencing decision of the district court.

JOHN K. BUSH, Circuit Judge. Courts do not rewrite, amend, or strike down statutes. We only “say what the law is.” Marbury v. Madison, 5 U.S. (1 Cranch) 137, 177 (1803). The district court held that a court conducting severability analysis defies that time-honored rule and instead “eliminat[es]” part of a statute. Lindenbaum v. Realgy, LLC, 497 F. Supp. 3d 290, 297 (N.D. Ohio 2020). It does not. We therefore reverse.

MURPHY, Circuit Judge. In Flast v. Cohen, 392 U.S. 83 (1968), the Supreme Court suggested that plaintiffs broadly have “standing” to sue over actions taken by the political branches whenever the litigants are sufficiently “adverse.” See id. at 100–01. The standing at issue in this case—associational standing—grew out of the same “judicial thinking” as Flast. Nat’l Automatic Laundry & Cleaning Council v. Shultz, 443 F.2d 689, 693 (D.C. Cir. 1971). It permits an association that has suffered no injury to sue on behalf of members who have. Yet the Court has since criticized Flast for overlooking that standing (and, in particular, its requirement that a plaintiff identify a personal injury) represents a key part of the Constitution’s separation of powers. Lewis v. Casey, 518 U.S. 343, 353 n.3 (1996). It is not clear how associational standing comports with this more recent guidance. At the least, the guidance should lead us to vigilantly ensure that an association’s members have incurred a personal injury. And here, the plaintiff (an association of physicians) failed to plausibly plead that any member has been injured by the actions of the Food and Drug Administration (FDA) that it criticizes. We thus affirm the dismissal of its complaint.

A mother and an unknown father were the subjects of a petition to terminate parental rights and to adopt a child. Only mother appeals. She argues that she lacked notice of the proceedings and that the petitioners failed to comply with the parental termination statutes. She also contests the statutory grounds relied on for terminating her parental rights and the trial court’s determination that termination was in her child’s best interest. We affirm the termination of the mother’s parental rights. But because the record does not reflect that the unknown father was served under the Tennessee Rules of Civil Procedure or the statutes governing substituted service, we vacate the judgment terminating his parental rights.

The Petitioner, Tommy Taylor, appeals as of right from the Lauderdale County Circuit Court’s summary dismissal of his petition for writ of habeas corpus, in which he contended that his thirteen-year sentence was illegal and that his guilty plea was void because the affidavit of complaint and arrest warrant were not signed by a magistrate or a neutral and detached court clerk. On appeal, the Petitioner contends that summary dismissal was improper and that the petition stated a cognizable claim for habeas corpus relief. Discerning no error, we affirm the judgment of the habeas corpus court.

A Dickson County jury convicted the defendant, Stephen C. Wallick, for the Class B felony of theft of property valued over $60,000 but less than $250,000. The trial court imposed a sentence of eight years in the Tennessee Department of Correction, suspended to supervised probation, and ordered the defendant pay $60,000 in restitution. The defendant filed this timely appeal, challenging the evidence supporting his conviction. Following our review, we affirm the judgment of the trial court.

Following a bench trial, the defendant, Christopher D. Todd, was convicted by the Robertson County Circuit Court with possession of marijuana with intent to sell, possession of marijuana with intent to deliver, and possession of drug paraphernalia, and he was sentenced to an effective term of eighteen months’ incarceration. On appeal, the defendant argues that he received ineffective assistance of counsel due to counsel’s failure to file a motion to suppress challenging the legality of the initial stop of his vehicle. Upon our review of the record and the applicable law, we affirm the judgment of the trial court.

The Defendant, Raymond Brandon Saffles, was charged by criminal information with one count of arson, and he entered a guilty plea to this charge the same day. See Tenn. Code Ann. § 39-14-301. The trial court, after accepting his plea agreement, sentenced the Defendant to six years, suspended this sentence, and then ordered the Defendant to serve 364 days in jail before serving six years on supervised probation. The trial court also ordered that the Defendant have no contact with the victim or her property and that restitution would be determined at a later hearing. Following this hearing, the trial court entered a restitution order requiring the Defendant to pay restitution in the amount of $99,017.78 with a payment schedule of $50 per month for the length of his probationary sentence, which the trial court determined to be six years. On appeal, the Defendant argues: (1) the trial court erred ordering him to pay nearly $100,000 in restitution and to pay $50 per month over the term of his probation; and (2) no amount of restitution is appropriate because his Social Security benefits are exempt from court-ordered collection under 42 U.S.C. § 407(a) and that even if his benefits are not exempt, he does not have the ability to pay any amount toward restitution. We reverse the judgment of the trial court as to restitution and remand this case for entry of a corrected judgment of conviction and probation order and for a new restitution hearing consistent with this opinion.

The Petitioner, Windie L. Perry, appeals from the Montgomery County Circuit Court’s denial of her petition for post-conviction relief from her convictions for two counts of especially aggravated kidnapping, two counts of aggravated child abuse, one count of facilitation of rape of a child, two counts of false imprisonment, and six counts of reckless endangerment and her effective twenty-year sentence. On appeal the Petitioner contends that the post-conviction court erred by denying relief on her ineffective assistance of counsel claims. We affirm the judgment of the post-conviction court.