SUTTON, Chief Judge. Early on a February morning in Lansing, Michigan, an officer noticed a man, later determined to be Jaron Morgan, seemingly passed out at the wheel of a stopped, still running, car. Without knocking on the car door, shining a flashlight into the car, or otherwise trying to arouse Morgan, the officer opened the car door and asked Morgan whether everything was okay. Morgan was groggy, and the officer asked for his identification. An altercation ensued. The officer arrested Morgan and found a firearm in the car and drugs on him, prompting a criminal indictment. The district court denied Morgan’s motion to suppress under the Fourth Amendment based on the community-caretaking doctrine, Morgan conditionally pleaded guilty, and the court sentenced him to 204 months. We reverse the district court’s denial of the motion to suppress.

CHAD A. READLER, Circuit Judge. Under Tennessee’s version of the Uniform Commercial Code, when is a bank entitled to a remedy (here, restitution) from a payee for mistakenly paying a negotiable instrument (here, a check)? And when does a payee take a check in “good faith” and “for value,” enabling the payee to defend against a payor bank’s claim for restitution? Those questions are posed here, as they were before the district court. At summary judgment, the district court held that two checks cashed at Commercial Bank and Trust were paid to Doug Goodman by “mistake” within the meaning of Tenn. Code Ann. § 47-3-418(b), and that Goodman could not demonstrate that he took the checks in good faith and for value, see id. § 47-3-418(c), entitling the Bank to restitution. We agree and thus affirm.

GRIFFIN, Circuit Judge. Plaintiffs are adherents to Christian Identity, a religion that is “explicitly racist.” Fox v. Washington, 949 F.3d 270, 273 (6th Cir. 2020). In its view, Caucasians are “God’s chosen people.” Id. at 274 (internal quotation marks omitted). After the Michigan Department of Corrections refused to recognize Christian Identity as a religion for purposes of the Michigan prison system, plaintiffs brought this declaratory judgment action under the Religious Land Use and Institutionalized Person Act of 2000, 42 U.S.C. § 2000cc et seq. (RLUIPA), requesting that the Department be directed to recognize Christian Identity as a religion. The district court affirmed the Department’s denial, and plaintiffs appealed.

In Fox, we held that plaintiffs satisfied the first two parts of the three-part RLUIPA test, but we remanded to the district court for the Department to sustain its “heavy burden” under a strict scrutiny analysis to show that its refusal to recognize Christian Identity as a religion furthered a compelling governmental interest, and, if so, that its denial was the least restrictive means of furthering such a compelling interest. 949 F.3d at 283.

On remand, the district court concluded that the Department met its burden and that refusing to recognize Christian Identity was the least restrictive means to ensure its compelling governmental interest. We disagree and hold that the Department failed to satisfy its burden of showing that its denial of recognition was the least restrictive means of furthering a compelling governmental interest. Alternatives, other than to simply accept or reject recognition, were available and included in the Department’s policies, but never considered by it.

Accordingly, we reverse the judgment of the district court and remand for entry of judgment in plaintiffs’ favor.

Defendant, Deshawn Eugene Williams, appeals from the Davidson County Criminal Court’s revoking his probation and ordering him to serve his previously ordered probationary sentence of ten years in confinement. On appeal, Defendant argues the trial court abused its discretion by failing to give him credit for time successfully served while on probation. After review, we affirm the judgment of the trial court.

Defendant, Michael E. Odom, was convicted by a Houston County jury of assault and elder abuse. The trial court imposed a two-year sentence, suspended to supervised probation after sixty days of incarceration. Defendant appeals the trial court’s order denying his motion for a new trial. On appeal, Defendant argues that the jury instruction on elder abuse was incomplete and that the trial court improperly commented on matters of fact during trial testimony. Following our review of the entire record, the briefs of the parties, and oral argument, we affirm the judgments of the trial court.

This appeal concerns the enforceability of a promissory note and a coguarantor’s right to seek contribution from another guarantor. The note and guaranties were assigned several times and, at one point, held by the coguarantor. On a motion for summary judgment, the trial court concluded on the undisputed facts that the promissory note had been discharged and that there was no right to contribution. We conclude that the promissory note was not discharged but agree that there was no right to contribution.

This appeal involves a bid awarded by a county finance department and upheld by the county’s finance committee after a bid protest hearing. One of the service providers whose bid was not selected filed a petition for common law writ of certiorari in chancery court. After reviewing the administrative record, the chancery court concluded that the finance committee’s decision was arbitrary and capricious and unsupported by material evidence and remanded for the county to rebid the contract. We reverse and remand for further proceedings.

More than 200 general counsel and chief legal officers have signed a letter of support for Legal Services Corporation (LSC) funding, the corporation reports. The letter urges Congress to strengthen its investment in equal justice and emphasizes the important role legal aid plays in creating financial stability for families who form “the foundation of a resilient middle class and healthy consumers” and maintains the “strength of the American workforce.” The corporation also reports that similar letters have been signed by 37 state attorneys general, 93 law school deans, 184 law firm leaders, and the presidents of the Conference of Chief Justices and Conference of State Court Administrators.

The Arts & Business Council's Volunteer Lawyers and Professionals for the Arts is joining the law firm of Bradley Arant Boult Cummings, Nashville Bar Foundation and Country Music Association to provide free legal services for nonprofits and Black-owned small businesses in Nashville on July 20. Advice will cover business formation, corporate governance, contracts and navigating local ordinances and state regulations. Eligible entities may receive up to one hour of assistance. Clients should sign up online. Attorneys should email vlpa@abcnashville.org to volunteer.

A federal judge last week dismissed a lawsuit brought by a group of Tennessee-born transgender plaintiffs hoping to compel the state to change the sex designations on their birth certificates. The plaintiffs had sought to overturn a 1977 law that generally prohibits such changes, the Tennessean reports. The group, represented by Lambda Legal, argued that the law discriminates against transgender people and leads to possible harassment and violence when birth certificates do not match gender identities. U.S. District Judge Eli Richardson wrote in his decision that while there are varying definitions of "sex," the term "has a very narrow and specific meaning" for the purpose of birth certificates: the "external genitalia at the time of birth." Read Richardson's opinion.