Petitioner, William Henry Smith Jr., was convicted of conspiracy to sell and deliver .5 grams or more of cocaine and received a fifteen-year sentence of imprisonment. The Petitioner filed a Rule 36.1 motion to correct an illegal sentence, which was summarily dismissed by the trial court. Petitioner raises the following issues for our review: (1) whether Petitioner’s allegation that he was erroneously classified as a career offender fails to state a colorable claim that his sentence is illegal; and (2) whether Petitioner’s right to due process of law was violated by the imposition of a sentence longer than what is required for a persistent offender. Upon review, we affirm the summary dismissal by the trial court.

Defendant-Appellant, Crystal Renae McCroskey, was indicted by a Knox County grand jury for one count of especially aggravated assault, three counts of aggravated kidnapping, one count of aggravated assault, and one count of domestic assault in violation of Tennessee Code Annotated sections 39-13-305, 39-13-304, 39-13-102, and 39-13-111. Pursuant to a plea agreement, the Defendant pled guilty to one count of aggravated assault as a Range II, Multiple Offender for an agreed sentence of eight years, with the manner of service to be determined by the trial court. As part of the agreement, the State dismissed the five remaining counts. Following a sentencing hearing, the trial court ordered the Defendant’s sentence to be served in confinement. On appeal, the Defendant argues that the trial court abused its discretion in denying her an alternative sentence. Upon review, we affirm the judgment of the trial court.

Following an automobile accident involving Appellant and Appellee, Appellant filed a civil warrant against Appellee’s automobile insurance carrier in the general sessions court. Later, after the statute of limitations had run, Appellant filed an amended civil warrant adding Appellee as a defendant. Together, Appellee and the insurance carrier filed a joint motion to dismiss, alleging that: (1) the statute of limitations barred Appellant’s claims against Appellee; and (2) the automobile insurance carrier was not a proper party to the lawsuit. The general sessions court granted the motion to dismiss. Thereafter, Appellant appealed the dismissal but did not file a new complaint in the trial court. Appellee and his insurance carrier moved to dismiss, and the trial court granted the motion. Discerning no error, we affirm.

In this divorce case, Wife takes issue with how the trial court distributed the possessory interest in the marital home and Husband’s Tennessee Consolidated Retirement System (“TCRS”) benefits. Because the trial court did not assign values to all of the relevant property subject to division, we vacate the judgment and remand the case to the trial court for additional findings.

For the week of April 5, 2021 - April 9, 2021

This appeal involves a challenge to the trial court’s dismissal of Plaintiff’s complaint. Specifically, Plaintiff contends that the trial court erred in finding that his complaint was deficient per the signature requirements in Rule 11.01(a) of the Tennessee Rules of Civil Procedure. For the reasons stated herein, we reverse the trial court’s dismissal of Plaintiff’s complaint and conclude it is in compliance with the requirements of Rule 11.01.

A Madison County jury convicted the defendant, Linda Holmes, of theft of property valued at $1000 or less for which the trial court imposed a sentence of 11 months and 29 days to be served in the county jail. On appeal, the defendant challenges the sufficiency of the evidence supporting her conviction. After reviewing the record and considering the applicable law, we affirm the judgment of the trial court.

A Weakley County jury convicted the defendant, Donald L. Elliott, of resisting arrest for which he received a sentence of six months with all but seven days suspended to supervised probation. On appeal, the defendant challenges the sufficiency of the evidence supporting his conviction. After a thorough review of the record, we affirm the jury’s verdict.

MURPHY, Circuit Judge. This case raises a recurring Fourth Amendment question. Suppose that the police uncover evidence that an individual is illegally selling drugs. When does that evidence create probable cause to search the individual’s home for drugs, drug proceeds, or other evidence of drug dealing? We have “struggled” to answer this question in a consistent way because it implicates two competing principles. United States v. Ardd, 911 F.3d 348, 351 (6th Cir. 2018). Under the first principle, probable cause to arrest a suspect for a crime does not necessarily create probable cause to search the suspect’s home. So our cases, at times, say that officers need additional evidence of a “nexus” between the drug dealing and the dealer’s home. United States v. Brown, 828 F.3d 375, 383–84 (6th Cir. 2016). Under the second principle, the probable-cause test allows officers to make common-sense conclusions about where people hide things. So our cases also say that evidence of a drug dealer’s ongoing drug activity can sometimes create this nexus to search the dealer’s home. United States v. Sumlin, 956 F.3d 879, 886 (6th Cir. 2020).

It can be difficult to decide which of these principles controls. The judicial disagreement in this case over whether the police had probable cause to search Terry Reed’s home proves the point. Relying on the second principle, a magistrate judge held that probable cause existed because an officer’s affidavit showed that Reed was a drug dealer engaged in ongoing drug activity. Relying on the first, the district court held that probable cause did not exist because the affidavit lacked other evidence connecting Reed’s drug activity to his home. Yet we need not decide who was right. This appeal concerns only whether the district court properly suppressed the evidence discovered during the search despite a state judge’s warrant to undertake it. Even when a search violates the Fourth Amendment, the Supreme Court has held that courts should not suppress evidence if the police reasonably relied on a judge’s decision that probable cause justified a warrant. United States v. Leon, 468 U.S. 897, 922–23 (1984). And given our “unsettled jurisprudence” on this nexus question, the police could reasonably rely on the judge’s finding that Reed’s ongoing drug activity provided probable cause to search his home. United States v. Hodge, 246 F.3d 301, 309 (3d Cir. 2001) (Alito, J.). Without deciding the thornier constitutional question, then, we hold only that the district court should not have suppressed the evidence. We reverse.

This appeal concerns the interplay between the Tennessee Health Care Liability Act (“HCLA”) and the common law on vicarious liability with respect to pre-suit notice in a health care liability claim against the principal only. We have determined that the provisions of the HCLA take precedence over the common law and that the plaintiff’s claims in this case were timely filed. Therefore, we reverse the decision of the trial court.