In her final Journal column, TBA President Tasha C. Blakney considers what the legal landscape would look like if there were no bar associations.

In the sixth and final installment of On the Road with TCB, the "Blakers" family pets are in the spotlight.

Catch up on the latest news from the TBA!

Reporters from across the state gathered in Nashville to learn about open meeting law, investigative journalism and more during the annual Reporters Workshop program, produced jointly by the Tennessee Bar Association, the Tennessee Association of Broadcasters and the Tennessee Press Association Foundation. Participants were selected from a record number of applicants who were interested in developing a deeper understanding of media law issues that may affect their everyday work, including access to government information, defamation and privacy concerns in reporting and other timely topics. Panelists included veteran reporters Demetria Kalodimos, Meribah Knight and Ben Hall, as well as legal media experts Paul McAdoo, Deborah Fisher and Seth May. The program continues tomorrow.

MURPHY, Circuit Judge. In this appeal, we must address how Article III’s “standing” requirements apply to class-action lawsuits. In individual litigation, a plaintiff lacks standing to sue a defendant if the plaintiff’s injuries are not “fairly traceable” to that defendant. DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 (2006) (citation omitted). Yet some courts have relied on the “juridical link” doctrine to jettison this standing element in the class setting. See, e.g., Payton v. County of Kane, 308 F.3d 673, 678–79 (7th Cir. 2002). According to these courts, that doctrine allows a named plaintiff in a putative class action to sue defendants who have not injured the plaintiff if these defendants have injured absent class members.

This case shows how the doctrine is supposed to work. When a Michigan county forecloses on a property because its owner has failed to pay property taxes, Michigan law permits the county to obtain ownership of the property outright—even if its value exceeds the taxes owed. That fate befell Thomas Fox. After he racked up some $3,000 in unpaid taxes, Gratiot County took his land. He valued the property at over $50,000, and the county treasurer sold it for over $25,000. But Fox did not see any of the surplus. We have held that similar conduct amounted to an unconstitutional “taking.” Hall v. Meisner, 51 F.4th 185, 187–88 (6th Cir. 2022). Fox thus filed a class action against Gratiot County on behalf of himself and similar landowners. But Fox did not stop there. He also sued 26 other counties that did not injure him, arguing that they engaged in the same conduct against other delinquent taxpayers. The district court certified a class, holding that Fox had standing to sue these other counties under the juridical link doctrine.

We cannot agree. This oddly named doctrine conflicts with the Supreme Court’s precedent holding that a class-action request “adds nothing to the question of standing[.]” Simon v. E. Ky. Welfare Rts. Org., 426 U.S. 26, 40 n.20 (1976). And Fox lacks standing to sue the 26 other counties under normal rules. Nor has he justified the doctrine with historical evidence. Although the English Court of Chancery permitted parties to file class-like “bills of peace,” Fox cites no case in which a plaintiff pursued litigation on behalf of absent parties against a defendant who had not harmed the plaintiff. The juridical link doctrine instead originates from dicta in a 1973 case that expressed a desire for the “expeditious” resolution of disputes. La Mar v. H & B Novelty & Loan Co., 489 F.2d 461, 466 (9th Cir. 1973). But expediency concerns cannot supplant Article III’s separation-of-powers protections. Hollingsworth v. Perry, 570 U.S. 693, 704–05 (2013). We thus vacate the certified class and remand for proceedings consistent with this opinion.

The Defendant, Rickey Haymer, appeals his convictions of crimes involving the attempted unlawful purchase or possession of a firearm. He argues that the evidence is insufficient to support his convictions because his actions in seeking to purchase a firearm did not constitute a “substantial step” toward the completed crimes. He also argues that the trial court committed plain error in admitting various text messages showing his contact with the putative seller. On our review, we respectfully affirm the judgments of the trial court.

The defendant, Joel Michael Guy, Jr., appeals his Knox County Criminal Court jury convictions of two counts of first degree premeditated murder, two counts of felony murder, and two counts of abuse of a corpse, challenging the denial of various motions to suppress evidence, the admission of certain evidence, the constitutionality of the statute prohibiting abuse of a corpse, and the sufficiency of the evidence supporting his convictions of abuse of a corpse and arguing that the cumulative effect of the errors entitles him to a new trial. Because the defendant did not have standing to challenge the warrantless entry into the house where the murders occurred, we affirm the denial of the defendant’s motion to suppress evidence seized from the crime scene on grounds different than those upon which the trial court relied. Even if the defendant had standing to challenge the entry into the house, the entry was supported by probable cause and exigent circumstances, and the evidence was in the officers’ plain view. The trial court correctly concluded that the search of the backpack was an appropriately-conducted inventory search. The trial court did not err by refusing to suppress surveillance video obtained using the receipts discovered from the unlawful search of the defendant’s Louisiana residence because the trial court correctly concluded that the police would have inevitably discovered the surveillance video during the course of the investigation. The trial court did not err by admitting evidence that the victims intended to stop providing financial support to the defendant. The proscriptive statute criminalizing the abuse of a corpse is not void for vagueness, and the evidence adduced at trial was sufficient to support the defendant’s convictions of these offenses. Finally, because we conclude that the trial court did not commit any error, no error obtains to accumulate. We affirm the judgments of the trial court.

A mother appeals from the termination of her parental rights to her child on the ground of severe child abuse. She concedes the ground for termination, but challenges the trial court’s finding that termination of her parental rights was in the child’s best interest. We affirm the trial court’s conclusion that clear and convincing evidence supports the aforementioned ground for termination and that termination is in the child’s best interest.

A father appealed an order requiring his children to receive the COVID-19 vaccine. While the appeal was pending, both children received the vaccine. Because we determine that the appeal is moot, we dismiss the appeal.

The 27th Annual Labor & Employment Forum set for May 5 in Nashville is a terrific opportunity to learn from some of the top professionals and judges in the labor and employment arena who will provide practical insight on emerging trends and critical issues. This year’s program features topics such as the new NLRB, FLSA case law update, a judicial panel of both state and federal judges, the ins and outs of effective mediations, and an ethics presentation on interviewing witnesses within the workplace.