For the week of May 1, 2023 - May 5, 2023

This is an administrative property tax appeal concerning the classification of real property for ad valorem tax purposes. This action originated with a taxpayer appeal of the property valuation by the Sevier County property assessor. On appeal, the administrative law judge re-classified the property as commercial, resulting in a tax assessment of 40% of the fair market property value. The Assessment Appeals Commission reversed the classification. The trial court affirmed the reversal. We now reinstate the commercial classification.

A Shelby County Criminal Court jury convicted the Defendant, Latosha Starks-Twilley, of first degree premeditated murder, and the trial court imposed a sentence of life imprisonment. On appeal, the Defendant argues: (1) the trial court erred in allowing the State to ask the defense expert prejudicial questions; (2) the trial court erred in allowing the State to ask the defense expert whether the Defendant met the criteria for antisocial personality disorder; (3) the trial court erred in prohibiting the defense from asking its own expert about whether the Defendant lacked the capacity to form the mens rea required for the offense; (4) the trial court erred in denying the Defendant’s request for the pattern jury instruction on reckless homicide; (5) the trial court erred in admitting certain photographs of the deceased victim into evidence; and (6) the evidence is insufficient to sustain her conviction. After review, we affirm the judgment of the trial court.

The defendant, Isaias Rodriguez, was convicted of rape of a child, a Class A felony, and sentenced to forty years at 100% in the Department of Correction. On appeal, the defendant argues: (1) there was insufficient proof of the forensic interviewer’s years of experience as required by statute for admission of the victim’s forensic interview; (2) the trial court erred in failing to make specific findings regarding the qualifications of the child advocacy center as required by statute for admission of the victim’s forensic interview; and (3) the evidence is insufficient to sustain the defendant’s conviction without the improperly admitted forensic interview of the victim. After review, we affirm the trial court’s finding regarding the interviewer’s years of experience and determine the defendant has waived his issue regarding the qualifications of the child advocacy center. In addition, we determine that the evidence is sufficient to sustain the defendant’s conviction. Therefore, we affirm the judgment of the trial court.

The Defendant, Tavarius Goliday, was convicted in the Montgomery County Circuit Court of first degree premeditated murder, conspiracy to commit first degree murder, and reckless endangerment with a deadly weapon and received an effective sentence of life in confinement. On appeal, the Defendant contends that the trial court erred by overruling his objection to evidence about a gang-related tattoo on his hand and that the evidence is insufficient to support his convictions. Based upon the oral arguments, the record, and the parties’ briefs, we affirm the judgments of the trial court but remand the case for correction of the judgment of conviction as to count one, first degree murder.

The Petitioner, Eric Foster, appeals the Knox County Criminal Court’s dismissal of his petition for post-conviction relief from his convictions for one count of aggravated rape, two counts of rape, one count of statutory rape, and one count of exhibition of harmful material to a minor. On appeal, the Petitioner argues that the post-conviction court erred by dismissing his petition for post-conviction relief as untimely. The Petitioner argues that he is entitled to due process tolling of the statute of limitations because he pursued his rights diligently and there were extraordinary circumstances preventing his timely filing. We affirm the judgment of the post-conviction court.

The notice of appeal in this case was not timely filed. Therefore, this Court lacks jurisdiction to consider this appeal.

MURPHY, Circuit Judge. In this appeal, we must address how Article III’s “standing” requirements apply to class-action lawsuits. In individual litigation, a plaintiff lacks standing to sue a defendant if the plaintiff’s injuries are not “fairly traceable” to that defendant. DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 (2006) (citation omitted). Yet some courts have relied on the “juridical link” doctrine to jettison this standing element in the class setting. See, e.g., Payton v. County of Kane, 308 F.3d 673, 678–79 (7th Cir. 2002). According to these courts, that doctrine allows a named plaintiff in a putative class action to sue defendants who have not injured the plaintiff if these defendants have injured absent class members.

This case shows how the doctrine is supposed to work. When a Michigan county forecloses on a property because its owner has failed to pay property taxes, Michigan law permits the county to obtain ownership of the property outright—even if its value exceeds the taxes owed. That fate befell Thomas Fox. After he racked up some $3,000 in unpaid taxes, Gratiot County took his land. He valued the property at over $50,000, and the county treasurer sold it for over $25,000. But Fox did not see any of the surplus. We have held that similar conduct amounted to an unconstitutional “taking.” Hall v. Meisner, 51 F.4th 185, 187–88 (6th Cir. 2022). Fox thus filed a class action against Gratiot County on behalf of himself and similar landowners. But Fox did not stop there. He also sued 26 other counties that did not injure him, arguing that they engaged in the same conduct against other delinquent taxpayers. The district court certified a class, holding that Fox had standing to sue these other counties under the juridical link doctrine.

We cannot agree. This oddly named doctrine conflicts with the Supreme Court’s precedent holding that a class-action request “adds nothing to the question of standing[.]” Simon v. E. Ky. Welfare Rts. Org., 426 U.S. 26, 40 n.20 (1976). And Fox lacks standing to sue the 26 other counties under normal rules. Nor has he justified the doctrine with historical evidence. Although the English Court of Chancery permitted parties to file class-like “bills of peace,” Fox cites no case in which a plaintiff pursued litigation on behalf of absent parties against a defendant who had not harmed the plaintiff. The juridical link doctrine instead originates from dicta in a 1973 case that expressed a desire for the “expeditious” resolution of disputes. La Mar v. H & B Novelty & Loan Co., 489 F.2d 461, 466 (9th Cir. 1973). But expediency concerns cannot supplant Article III’s separation-of-powers protections. Hollingsworth v. Perry, 570 U.S. 693, 704–05 (2013). We thus vacate the certified class and remand for proceedings consistent with this opinion.

The Defendant, Rickey Haymer, appeals his convictions of crimes involving the attempted unlawful purchase or possession of a firearm. He argues that the evidence is insufficient to support his convictions because his actions in seeking to purchase a firearm did not constitute a “substantial step” toward the completed crimes. He also argues that the trial court committed plain error in admitting various text messages showing his contact with the putative seller. On our review, we respectfully affirm the judgments of the trial court.

The defendant, Joel Michael Guy, Jr., appeals his Knox County Criminal Court jury convictions of two counts of first degree premeditated murder, two counts of felony murder, and two counts of abuse of a corpse, challenging the denial of various motions to suppress evidence, the admission of certain evidence, the constitutionality of the statute prohibiting abuse of a corpse, and the sufficiency of the evidence supporting his convictions of abuse of a corpse and arguing that the cumulative effect of the errors entitles him to a new trial. Because the defendant did not have standing to challenge the warrantless entry into the house where the murders occurred, we affirm the denial of the defendant’s motion to suppress evidence seized from the crime scene on grounds different than those upon which the trial court relied. Even if the defendant had standing to challenge the entry into the house, the entry was supported by probable cause and exigent circumstances, and the evidence was in the officers’ plain view. The trial court correctly concluded that the search of the backpack was an appropriately-conducted inventory search. The trial court did not err by refusing to suppress surveillance video obtained using the receipts discovered from the unlawful search of the defendant’s Louisiana residence because the trial court correctly concluded that the police would have inevitably discovered the surveillance video during the course of the investigation. The trial court did not err by admitting evidence that the victims intended to stop providing financial support to the defendant. The proscriptive statute criminalizing the abuse of a corpse is not void for vagueness, and the evidence adduced at trial was sufficient to support the defendant’s convictions of these offenses. Finally, because we conclude that the trial court did not commit any error, no error obtains to accumulate. We affirm the judgments of the trial court.