This appeal involves a mother’s post-divorce petition for modification of alimony and child support. Because the trial court has not disposed of all of the claims raised in the mother’s petition, we dismiss the appeal for lack of a final judgment.

JULIA SMITH GIBBONS, Circuit Judge. S.C., a high school student at the inception of this case, sued the Metro Nashville Public Schools (“MNPS”) under Title IX and 42 U.S.C. § 1983, alleging that MNPS was deliberately indifferent to student-on-student harassment that she suffered related to her sexual assault and later participation in a sexual misconduct investigation. In her suit, S.C. raised three types of claims: a Title IX “before” claim, alleging deliberate indifference by MNPS before she was assaulted; a Title IX “after” claim, alleging deliberate indifference by MNPS during the school’s investigation into her harassment; and Fourteenth Amendment equal protection claims brought under 42 U.S.C. § 1983.

S.C.’s Title IX “before” claim was dismissed at the summary judgment phase, but the remaining claims proceeded to trial. After a bench trial, the court found MNPS liable for emotional distress and other damages on the Title IX “after” claim, but not liable under § 1983. The parties now cross-appeal the judgment, and S.C. also appeals the grant of summary judgment to MNPS on the other Title IX claims.

Because the district court lacked the benefit of our ruling in Doe v. Metro. Gov’t of Nashville & Davidson Cnty., 35 F.4th 459 (6th Cir. 2022), cert. denied sub nom. Metro. Gov’t of Nashville & Davidson Cnty. v. Doe, 143 S. Ct. 574 (2023), we vacate and remand the court’s grant of summary judgment to MNPS on the Title IX “before” claim and the § 1983 “before” claim. However, we affirm both the trial court judgment that MNPS is liable on S.C.’s Title IX “after” claim and the damages award.

The TBA Appellate Practice Section will host a free webinar on Dec. 12 at noon CST to review of the nuts and bolts of e-filing in Tennessee appellate courts. Panelists will provide tips on best practices and share feedback from appellate court clerks on how to successfully navigate the appellate e-filing system. Questions are welcome. Learn more and register.

Join us Dec. 7 at noon for a live webcast on Corporate Counsel 2023: Ethical Issues with Laura Chastain, ethics counsel for the Board of Professional Responsibility. Chastain will discuss Formal Ethics Opinion 2022-F-168, other new ethics opinions and ethics for in-house counsel.

The state Supreme Court reinstated the license of Davidson County attorney Lauren Suzanne Wachsman today, retroactive to Nov. 9. Wachsman was placed on inactive status more than five years ago on May 21, 2018.

While the holiday season can be a joyful time for some, the pressures and stressors of work and life escalate for others. The TBA Attorney Well Being Committee will provide a webinar and empathetic conversation about the difficulties that professionals encounter during the season and how to navigate through them for a healthier experience. Panelists will discuss real issues faced by today's lawyers and explore resources available to assist. This event is free for TBA members. Register here.

The TBA Appellate Practice Section will host a free webinar on the nuts and bolts of e-filing in the Tennessee appellate courts. In this webinar, panelists will provide tips on best practices, lessons learned and share feedback from the appellate court clerks on common issues and problems to help you successfully navigate the appellate e-filing system. The presenters will set aside time for questions, so come prepared to listen, learn and engage. One hour of general CLE credit is available for a $50 processing fee. Register now.

State Rep. Justin Jones, D-Nashville, told a forum for Black journalists at Howard University on Tuesday that a “lack of democracy is what brought attention to Tennessee," according to the Commercial Appeal. Jones, known for his activism, highlighted his strategy behind demonstrating in the House chamber. “What we're not talking about is the movement to ban assault weapons that are terrorizing ... our schools” said Jones. The forum was sponsored by the Center for Journalism and Democracy.

There have been a number of Tennessee statutory updates this year of which criminal law practitioners should be aware. Lawmakers voted on consequential legislation involving RICO law expansion, DUIs and driving offenses, juveniles and more. Several procedural changes were made as well. View a comprehensive list of updates here.

Community activist and former Shelby County commissioner Tami Sawyer announced yesterday she is challenging incumbent Joe Brown in next year's race for General Sessions Court clerk, the Commercial Appeal reports. Sawyer said in a press release "we are at a dangerous crossroad in Shelby County at the intersection of crime and poverty." The General Sessions Court clerk election will be held March 2024. Brown was elected in 2019 and previously served as the Memphis City Council Super District 8 Position 1 representative for 21 years.