Join your colleagues for the CLE webcast Digital Signatures on Sept. 14, noon to 1 p.m. CDT featuring guest speaker Jeff Schoenberger. One of the last bastions of “paper is king” is the executed document – “wet” signatures serving as proof that a certain person signed a document. This is true to a point. This seminar will explore all things “digital signature” and will start you down the right path for a digital John Hancock. Find our more and register.

The TBA Young Lawyers Division is now accepting applications for its Diversity Leadership Institute (DLI) Class of 2024. DLI is a six-month leadership and mentoring program for Tennessee law students in their second, third or fourth years of study. Class size is limited to 20 to 25 students selected from across the state. The goal of the program is to have a diverse class, so selection is based in part on race, ethnicity, gender, age, sexual orientation, gender identity, disability, background, geographical factors and law school attended. The application deadline is 5 p.m. CDT on Nov. 5. There will be a mandatory zoom meeting on Nov. 8 at 5:30 p.m. CST. All are encouraged to apply. This year's DLI co-coordinators are YLD Board members Brande Boyd and Rod Watson.

MURPHY, Circuit Judge. Legacy Medical Transport, a small family-owned business, provides nonemergency ambulance services in several Ohio counties that border Kentucky. After receiving many inquiries from Kentucky hospitals and nursing homes, Legacy sought to expand into the Commonwealth. But Kentucky required Legacy to show a “need” for its services and to apply for a “certificate of need” with the Kentucky Cabinet for Health and Family Services. Unsurprisingly, existing ambulance providers (Legacy’s potential competitors) objected to Legacy’s request. The Cabinet denied Legacy’s application partly on the ground that these providers offered an adequate supply. Legacy then sued various Cabinet officials, alleging that Kentucky’s certificate-of-need law violated the “dormant” or “negative” part of the Commerce Clause. The district court granted summary judgment in favor of the Cabinet officials. We affirm in part and reverse in part.

DAVIS, Circuit Judge. Yi Zhang Lin, a native and citizen of China, petitions for review of the Board of Immigration Appeals’ (“BIA” or “the Board”) final order affirming an immigration judge’s (“IJ”) denial of his requests for asylum, withholding of removal, and protection under Article III of the Convention Against Torture (“CAT”). The question before us is whether the BIA’s determinations are supported by substantial evidence. As will be explained below, the BIA’s rationale does not allow us to make that determination. So we grant Lin’s petition and remand for further proceedings.

KAREN NELSON MOORE, Circuit Judge. Kentucky State Police officers searched Edward Lewis’s laptop, cell phone, and thumb drive and found evidence of child pornography. Lewis moved to suppress the evidence, arguing that it was obtained through an unlawful search and seizure of his electronic devices. The district court found that the good-faith exception to the exclusionary rule applied and denied Lewis’s motion, and Lewis pleaded guilty while reserving his right to bring this appeal. We REVERSE the district court’s order denying Lewis’s motion to suppress, VACATE Lewis’s conviction, and REMAND for further proceedings.

The Legal Aid Society of Middle Tennessee and the Cumberlands (LAS) will host nine legal clinics in Nashville during September, two of which will be veterans only clinics. For information on dates, times and locations, visit the LAS website.

Defendant, Christopher David Pace, entered a partially open plea in which the length of his sentence was agreed upon. The trial court would determine the manner of service at a separate sentencing hearing. On appeal, Defendant argues that the trial court erred because it relied only upon a “Specific Data Report” in sentencing Defendant. Alternatively, Defendant argues that the trial court abused its discretion in denying Defendant’s request for alternative sentencing. The State concedes that it was reversible error for the trial court to sentence Defendant without a presentence report. We find that the trial court erred in failing to consider the validated risk and needs assessment as required by Tennessee Code Annotated section 40-35-210(b)(8). However, we conclude that the issue is waived. We further conclude that the trial court did not abuse its discretion in denying Defendant’s request for alternative sentencing. We accordingly affirm the judgment of the trial court.

The annual Access to Justice Awards were presented to six outstanding legal community leaders as part of Equal Justice University in Murfreesboro. The awards recognized Supreme Court Justice Sharon Lee, Judge Suzanne Bauknight, Chancellor Ellen Hobbs Lyle, Allison Jones, Elizabeth Leiserson and Julie Yriat. Retiring Justice Lee received the Lifetime Achievement Award in recognition of her exceptional contributions to the civil justice system. U.S. Bankruptcy Judge Bauknight received the Janice M. Holder Access to Justice Award in recognition of her role in creating the statewide virtual debt relief clinic model. Chancellor Lyle and Legal Aid Society of Middle Tennessee & the Cumberlands (LAS) attorney Jones were both recognized with the B. Riney Green Access to Justice Award for their work in promoting successful inter-program cooperation across the state. Finally, LAS attorney Leiserson and Yriat, legal director at the Nashville Hispanic Bar Association, were recognized as New Advocates of the Year, both working with the Eviction Right to Counsel Project in Davidson County. Read more about the annual ATJ Awards on the Tennessee Alliance for Legal Services website. The conference wrapped up today with a keynote address by Legal Services Corporation President Ron Flagg, who noted LSC's priority focus on innovation and technology to support legal services and better leverage pro bono initiatives. See photos from today's event.

Tennessee Attorney General Jonathan Skrmetti joined 15 other state attorneys general in urging the U.S. Securities and Exchange Commission (SEC) to require any foreign-owned company to certify via an independent process that it is compliant with Section 307 of the Tariff Act of 1930, which prohibits the import of any product manufactured wholly or in part by forced labor as a condition of being listed on a U.S. based securities exchange. The attorneys general question the business practices and reports of alleged forced labor of the Chinese fast-fashion retailer SHEIN, which is potentially launching an initial public offering (IPO) later this year.

United States Attorney Kevin G. Ritz yesterday traveled to Dyer County in the 29th Judicial District of West Tennessee to host a series of roundtable discussions with law enforcement, local prosecutors and community stakeholders. Roundtable participants had an open dialogue with the U.S. Attorney, addressing their issues and concerns and learning more about the department’s priorities, which include addressing gun violence.