This is an appeal from a final judgment in a conservatorship case. Because the appellant did not file her notice of appeal with the clerk of the appellate court within thirty days after entry of the final judgment as required by Tennessee Rule of Appellate Procedure 4(a), we dismiss the appeal.

The White House recently sent a supplemental funding request to Congress that includes $21 million in disaster relief funds for the Legal Services Corporation (LSC). The agency reports this is the first time that such funding has been included in a disaster relief request. Following natural disasters, the LSC works with state partners to provide resources and information vital for communities to respond and recover. Among its initiatives, the agency hosts a Disaster Task Force and recently launched a new website designed to provide real-time disaster risk assessments, details on recent disasters, recovery guidance, connections to local aid organizations and comprehensive information for each disaster type. The group also recently featured a conversation about the role civil legal aid plays in recovery efforts in its podcast “Talk Justice.”

In this appeal of a compensation order granting summary judgment to the employer, the employee argues there are multiple disputed questions of material fact regarding whether the injury arose primarily out of his employment. The employee was working as a manager of an automobile repair store in July 2021 when he and a co-worker began discussing the possible sale of a gun. Subsequently, the co-worker accidentally shot the employee, causing extensive injuries. The employee sought workers’ compensation benefits, and the employer filed a motion for summary judgment, arguing that the injury did not arise primarily out of the employment as purchasing a personal weapon and the presence of a gun were not risks inherent to managing an automobile repair shop. The employee argued there were questions of material fact regarding, among other things, whether the injured employee asked to see the gun, whether the employer knew that its employees regularly brought guns to work, and whether the employee handled the gun in an effort to disarm it for the safety of the store and general public. The trial court granted the employer’s motion for summary judgment, and the employee has appealed. Following careful review of the record and the arguments of counsel, we reverse the grant of summary judgment and remand the case for additional proceedings.

The Memphis Lawyers’ Chapter of the Federalist Society will hold a virtual event on Nov. 29 from noon to 1 p.m. CST featuring Christopher J. Walker of the University of Michigan Law School. Walker will discuss the current state and future of the U.S. Supreme Court’s “Chevron Doctrine.” Those interested in attending may register online or contact Greg Grisham, 901-333-2076.

Earlier this week, Tennessee Attorney General Jonathan Skrmetti joined 25 other state attorneys general in sending a letter to Congress requesting the passage of H.R. 1337, the Immigration Enforcement Partnership Act of 2023. If signed into law, the bill would grant state attorneys general the authority to enforce certain federal immigration laws. Read more about the issue or read the letter.

The YWCA Nashville & Middle Tennessee will hold its next “Stand Against Injustice” webinar on Nov. 29 from noon to 1 p.m. CST. This month’s installment of the monthly series will focus on the state’s decision not to accept federal funds for health care. Panelists will discuss statistics related to maternal mortality, hospital closures and medical bankruptcies. Learn more or register online.

Four of the 15 largest law firms in Nashville are vying to represent the newly reinstated airport board, Nashville Business Journal reports. They are: Adams and Reese LLP; Butler Snow; Gullett Sanford Robinson & Martin PLLC; and Neal & Harwell PLC. The board was set to meet today and consider the bids. While the board’s bylaws provide for a general counsel, members have argued they need outside counsel following the state’s attempt to appoint its own members to oversee the Nashville International Airport and the smaller John C. Tune Airport. Read more about the firms seeking to fill the role.

The Ethical Campaign is back for 2023 as a live virtual program on Dec. 6. This advanced level program for state and local lawmakers, judges, candidates for executive, judicial or legislative positions, and campaign chairs, treasurers and counsel will include all aspects of the law and ethics of election for office. Topics include the ethical issues involved in compliance with election law provisions, compliance with campaign finance practices, conformity with the “Comprehensive Governmental Ethics Reform Act,” and an analysis of the provisions of the Code of Judicial Conduct and Rules of Professional Conduct touching on elections. Make plans to join in online from 1-4:15 p.m. CST.

The TBA Law Tech Section is excited to offer three different law tech themed lunch and learn programs in three cities across the state of Tennessee featuring local speakers. The Knoxville program will take place on Dec. 15 and will focus on cybersecurity. The first session will provide an update on changes in the cybersecurity landscape, while the second session will provide resources to help attorneys assist clients who are victims of cybersecurity attacks and address unique concerns for specific client industries (e.g., health care, financial, educational). Then, join us in early February for the Nashville program, which will feature a special two hour edition of "The Bill & Phil Show." The 2024 rendition of this popular session will explore the practical applications of Artificial Intelligence (AI) in the real world both in legal-specific technology and in productivity gadgets used by professionals of all stripes. Come with all the tech questions and expect to see a variety of tech gadget demos! Since AI is such a hot, ever-evolving topic, the mid-March Memphis program also will focus on AI by providing a general introduction followed by a session focusing on the ethical implications of this booming technology. This program is perfect for beginners!

Check out the programs, and sign up today!

Pursuant to a plea agreement, the Defendant, acting pro se, entered guilty pleas to various felony offenses and received an effective sentence of six years’ imprisonment. A few weeks later, the Defendant filed a motion to withdraw his guilty pleas, claiming they were unknowing and involuntarily entered because he was not advised of the consequences of the guilty pleas.1 Following a hearing, the trial court denied the Defendant’s motion. For the first time in this appeal, the Defendant claims that his waiver of his Sixth Amendment right to counsel was not knowingly and voluntarily entered; therefore, his subsequent guilty pleas were constitutionally invalid. The Defendant additionally claims the trial court abused its discretion in denying his motion to withdraw his guilty pleas and determining that his guilty pleas were knowingly and voluntarily entered. Upon our review, we conclude that the trial court’s investigation of the factors bearing upon the Defendant’s knowing and intelligent waiver of his right to counsel complied with Faretta v. California, 422 U.S. 806 (1975), and Iowa v. Tovar, 541 U.S. 77 (2004). We further conclude that the Defendant failed to establish that manifest injustice required the withdrawal of his guilty pleas. Accordingly, we affirm the judgments of the trial court.