On March 20, the Tennessee Supreme Court ordered former Nashville attorney Brian Manookian to pay the Board of Professional Responsibility $30,251.50 in costs associated with his disciplinary proceedings. The court had notified Manookian of the assessment, allowing him to contest the amount. It said today that it had not received an objection from him in the time permitted. The court permanently disbarred Manookian on Feb. 16.

A three-judge panel of the 5th U.S. Circuit Court of Appeals has blocked a Texas law allowing state law enforcement to arrest individuals suspected of entering the United States without documentation, Axios reports. The action comes just hours after the U.S. Supreme Court allowed the state to enforce the law while the issue is appealed, but directed the appeals court to act quickly on a “stay pending appeal,” noting that the court previously had imposed only a “temporary administrative stay.” Justices Amy Coney Barrett and Brett Kavanaugh wrote a separate opinion saying they would not have intervened in the case at this point. The Biden administration is challenging the law, arguing that immigration enforcement is solely the responsibility of the federal government. SCOTUSblog has more on the case.

BLOOMEKATZ, Circuit Judge. The MetroHealth System, an Ohio hospital, denied all employee requests for religious exemptions from its COVID-19 vaccine mandate. It granted some employee requests for medical exemptions. A little over a month later, MetroHealth changed its mind about the religious exemption requests and granted all of them. Frank Savel, a former MetroHealth employee who resigned shortly after the hospital rejected his religious exemption request, sued MetroHealth for religious discrimination. He argued that the exemption process—especially the blanket denial of religious exemptions—violated Title VII and Ohio Revised Code § 4112. Forty-five other current or former employees joined him. Most still worked at MetroHealth when they filed their complaint, but some had resigned for reasons related to the exemption process.

The district court dismissed the action for lack of subject matter jurisdiction and failure to state a claim upon which relief could be granted. The court reasoned that the plaintiffs who were still employed at MetroHealth when they filed their complaint had no standing to sue and, in the alternative, that they failed to state claims under Title VII and § 4112. It concluded that the plaintiffs who resigned by the time the complaint was filed did have standing, but that they also failed to state claims under Title VII and § 4112. The plaintiffs appeal, arguing that they have standing and that they stated claims upon which relief can be granted. We affirm as to Plaintiffs 3–46, but we reverse as to Plaintiffs 1 and 2.

BLOOMEKATZ, Circuit Judge. Sandra Sabastian-Andres, an indigenous Mayan Akateko woman from Guatemala now living in the United States, applied for asylum, withholding of removal, and protection under the Convention Against Torture. The Immigration Judge denied all three claims for relief, and the Board of Immigration Appeals affirmed. The Board agreed with the Immigration Judge that Sabastian-Andres did not demonstrate a nexus between her particular social group and the harm she experienced and did not show that the government of Guatemala acquiesced in her mistreatment there. Because the Board’s conclusions were supported by substantial evidence, we deny her petition for review.

A Rutherford County jury found Defendant, Lavondas C. Nelson, guilty of two counts of sale of more than 0.5 grams of cocaine within 1,000 feet of a school (Counts 1 and 2), and sale of more than 0.5 grams of cocaine (Count 3). The trial court sentenced him to forty years in the Tennessee Department of Correction (TDOC). On appeal, Defendant argues the evidence was insufficient to establish that he sold cocaine within a school zone, the trial court erred in failing to instruct the jury on entrapment, and his sentence is excessive. After review, we affirm the judgments of the trial court. However, we remand the case to the trial court for entry of revised judgments in Counts 1 and 2 that reflect the proper release eligibility for those offenses.

The Lawyers' Association for Women Marion Griffin Chapter will hold a celebration to honor its longtime Executive Director Melanie Gober Grand, who is retiring at the end of the month. The event will take place Tuesday from 5:30-7:30 p.m. CDT at the offices of Dodson Parker Behm & Capparella PC, 1310 6th Ave. N., Nashville 37208. Grand has served as director of the association for 24 years. Learn more or register to attend here.

Washington, Colorado and Minnesota are the latest states to transition to the NextGen bar exam, Reuters reports. Washington will begin using the overhauled bar exam when it first becomes available in July 2026. Minnesota will move to the test in 2027. Colorado will do so in 2028. They join 17 other jurisdictions that have announced plans to transition to the new test. In related news, Washington’s high court also approved “in concept” two new licensing pathways for law students, including a six-month apprenticeship program. The state joins New Hampshire, Oregon and Wisconsin in that approach.

U.S. News & World Report will release its 2024 law school rankings on April 9, amid predictions of possible methodology changes. According to Reuters, the publication is expected to modify its formula to make it more difficult for people to use publicly available American Bar Association (ABA) data to forecast results months in advance. U.S. News drastically altered its methodology in 2023 after nearly a quarter of law schools declined to provide any internal data, saying the publication's methodology hurt student diversity. As a result, the rankings were based primarily on ABA data such as employment rates and bar pass rates. That approach made it easier to project the rankings ahead of their official release and made it difficult to compare.

The 2024 TBA Leadership Law class met recently in Knoxville for its “Issues in Community Leadership” program. Class members heard from Tennessee Supreme Court Justice Dwight E. Tarwater, who spoke on “Leadership in 6 Words”; University of Tennessee College of Law Associate Professor and Clinical Programs Director Joy Radice, who spoke about pro bono efforts to expunge criminal charges and restore citizenship rights; LMU Duncan School of Law Professor Mohamed Akram Faizer, who presented on “Being Appreciative of Yourself and Others;” and Knoxville lawyer Robbie Pryor, with Pryor, Priest & Harber, who shared his experiences of navigating life as a lawyer. The group also heard from a number of community leaders, including Dr. Charles F. Lomax, president and chief executive officer of the Knoxville Area Urban League; Rev. Reneè Kesler, president of the Beck Cultural Exchange Center; and attorney Chloe Akers, president and founder of The Best of Tennessee Inc.

This new 1-Click package includes a variety of videos produced by the TBA Law Tech section during the 2023-2024 bar year. Topics include best practices for attorney cybersecurity, guiding clients through a cybersecurity attack, harnessing ChatGPT and generative AI in your law practice, and a special two-hour "Bill & Phil Show." This package offers six hours of dual CLE credit. As a member of the TBA Law Tech Section, you always will receive a discount on CLE programming produced by the section.