In this case involving termination of the father’s and mother’s parental rights to two of their minor children, the trial court determined that three statutory grounds had been proven as to each parent by clear and convincing evidence. The trial court further determined that clear and convincing evidence demonstrated that termination of the father’s and mother’s parental rights was in the children’s best interest. The father and mother have each appealed. Discerning no reversible error, we affirm.

Michael Regier, general counsel and secretary at Vanderbilt University Medical Center (VUMC), will retire at the end of the academic year, and Douglas Mefford, managing counsel in the Office of Legal Affairs, will succeed him effective July 1, according to a press release from VUMC. Mefford joined VUMC in 2013 and has led initiatives to restructure the LifeFlight air ambulance program and Vanderbilt Imaging Services. He has also supported the Medical Center’s regional hospital acquisitions in Lebanon, Shelbyville and Tullahoma, and helped negotiate VUMC’s minority interest in Tennova Healthcare – Clarksville.

Memphis Area Legal Services Inc. (MALS) has announced that Loyce Lambert Ryan has joined the organization as interim executive director following the departure of Cindy Ettingoff. Lambert Ryan served as judge for the Shelby County General Sessions Criminal Court Division XV from 2000 to 2022. She was appointed in 2004 by then-Gov. Phil Bredesen to the Governor’s Task Force on Sentencing Guidelines, and in 2015 by the Tennessee Supreme Court to serve on the Indigent Defense Task Force. Additionally, MALS has appointed Gortria C. Banks as chief operating officer. She joined MALS in August 2023 after serving as associate executive director of the Community Legal Center. Read more in a press release from the organization.

MURPHY, Circuit Judge. The doctrine of qualified immunity insulates public officials from liability under 42 U.S.C. § 1983 unless the caselaw existing at the time of their actions clearly established that they violated the Constitution. There often will not be much difference between the then-existing law and the current law. As this case shows, however, this distinction can sometimes matter.

In July 2018, Brian Lawler tragically committed suicide at a county jail. To hold officers liable for failing to prevent a pretrial detainee’s death at that time, our caselaw required proof that the officers subjectively believed that there was a strong likelihood the inmate would commit suicide. See Grabow v. County of Macomb, 580 F. App’x 300, 307–09 (6th Cir. 2014). Today, however, our court would hold officers liable if they recklessly overlooked a pretrial detainee’s strong likelihood of suicide—even if they did not subjectively recognize it. See Helphenstine v. Lewis County, 60 F.4th 305, 316–17 (6th Cir. 2023). When denying qualified immunity to the officers sued in this case, the district court held that a reasonable jury could find that they “recklessly disregarded” the strong risk that Lawler would commit suicide. But that standard governs today; it did not govern when Lawler committed suicide in 2018. And when we apply the correct test, the evidence shows that the officers did not subjectively believe that Lawler was likely to take his life. We thus reverse the district court’s denial of qualified immunity to the officers.

Defendant, Karla Marie Clausell, appeals as of right from her conviction for first degree premeditated murder, for which she is serving a life sentence. On appeal, Defendant contends that the trial court erred by admitting evidence from Snapchat in violation of Tennessee Rule of Evidence 404(a) and by admitting Snapchat and Facebook messages in violation of Tennessee Rule of Evidence 404(b). She also contends that the cumulative effect of these errors entitles her to a new trial. After a thorough review of the evidence and applicable case law, we affirm.

Granville Williams, Jr., died while residing at an assisted-living facility. The central question in this appeal is whether his son’s ensuing wrongful-death action against the facility must be arbitrated. To answer that question, we must resolve two subsidiary issues—first, whether the attorney-in-fact who signed the arbitration agreement as Williams’s representative had authority to do so and, second, whether Williams’s son and other wrongful-death beneficiaries who were not parties to the arbitration agreement nevertheless are bound by it. We hold that signing an optional arbitration agreement—that is, one that is not a condition of admission to a health care facility—is not a “health care decision” within the meaning of the Durable Power of Attorney for Health Care Act. The durable power of attorney that gave Williams’s attorney-in-fact authority to act for him in “all claims and litigation matters” thus provided authority to enter the optional arbitration agreement even though it did not specifically grant authority to make health care decisions. We further hold that Williams’s son is bound by the arbitration agreement because his wrongful-death claims are derivative of his father’s claims. Because we conclude that the claims in this action are subject to arbitration, we reverse the Court of Appeals’ contrary decision and remand to the trial court.

In this lawyer disciplinary case, the lawyer’s conduct compels disbarment. The lawyer sent a series of intimidating, demeaning, embarrassing, and harassing communications to opposing counsel and others. Some targeted family members of opposing counsel, including one family member who was also a former client, and caused well-founded concern for their well-being and safety. In the ensuing disciplinary proceedings, a Board of Professional Responsibility hearing panel found that the purpose of the communications was to intimidate opposing counsel in order to gain unfair advantage in pending litigation. It concluded inter alia that the lawyer’s conduct was prejudicial to the administration of justice, that he failed to respect the rights of third persons, and that he violated his duty to a former client, in violation of Tennessee’s Rules of Professional Conduct. The hearing panel said the presumptive sanction was disbarment, found four aggravating factors, and found no mitigating circumstances. Without explanation, the hearing panel recommended a two-year suspension instead of disbarment. The attorney appealed to the trial court. The trial court indicated that, had the Board of Professional Responsibility filed a separate petition for review, the trial court would have recommended disbarment, but because the Board did not, the trial court affirmed the sanction of suspension. Both parties appeal. Here, the lawyer’s conduct was egregious. Victimizing the families of opposing counsel and causing concern for their well-being and safety is an especially grave offense and a profound dishonor as a lawyer. The hearing panel’s decision to deviate downward from the presumptive sanction of disbarment was arbitrary and capricious, and the lawyer must be disbarred. Accordingly, we modify the judgment of the hearing panel and impose the sanction of disbarment.

A group of women suing Johnson City and multiple police officers is now accusing city officials of victim-shaming, pushing back against public statements suggesting they deserve blame for being victims of an alleged serial rapist, the Tennessee Lookout reports. Johnson City Manager Cathy Ball has said the victims could be, to some degree, “at fault” for their assaults because they “consumed and partook of illegal drugs.” The lawsuit alleges mishandling of the investigation into local businessman, Sean Williams, and claims officers with the Johnson City Police Department took hundreds of thousands of dollars in cash from Williams while refusing to take meaningful steps to "stop his sexually predatory behavior," News Channel 9 reported in December. “Survivors deserve to be treated with respect,” one Jane Doe said. Ball said in a statement that “protecting victims and the community is the top priority of the Johnson City Police Department."

Make plans now to attend a May 2 webcast to hear from a representative of the Tennessee Department of Revenue, who will provide an introduction to the state franchise and excise tax. The event will begin at noon CDT and provide one general CLE credit. More information coming soon!

Legal technology and TBA member advantage company Clio has announced it will heighten its focus and investment on technology for mid-sized law firms of more than 20 employees, according to the legal blog LawSites. Clio states that more than 1,000 mid-sized law firms already subscribe to its services, so it will more heavily invest in products tailored to that market. In conjunction with the announcement, Clio released its 2024 Legal Trends for Mid-Sized Firms report, which finds a significant discrepancy in the adoption of cloud-based legal practice management software between mid-sized and smaller law firms, signaling a potential gap in artificial intelligence readiness and technological integration across the mid-sized segment.