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Posted by: Azya Thornton on Mar 13, 2025

KAREN NELSON MOORE, Circuit Judge. This appeal concerns issues of standing and mootness in a putative class-action suit. According to Bradley Patton, state and local officials in Rutherford County, Tennessee unconstitutionally require pre-trial detainees to prove in a hearing before the state court that any bail funds equal to or in excess of $75,000 were not derived directly or indirectly from criminal activities. On June 13, 2023, Patton requested permission to post $100,000 to cover outstanding bail. Despite having the funds ready to secure his release, Patton was not released from custody. Under Rutherford County’s local rules, Patton had to wait for the state court to schedule a hearing to determine whether the bail money was sourced from any criminal activities. Patton filed this putative class action in federal court claiming that this local rule violated his and the putative class’s due-process and Eighth Amendment rights. For the reasons that follow, we REVERSE the district court’s judgment dismissing Patton’s claims on jurisdictional grounds and REMAND for proceedings consistent with this opinion.

Posted by: Azya Thornton on Mar 13, 2025

CHAD A. READLER, Circuit Judge. Inspired by the Sentencing Commission’s retroactive amendment of a relevant guidelines provision, Kevin Obi asked the district court to reduce his sentence. The district court did so, but in an admittedly modest fashion: it reduced Obi’s 300-month sentence to 293 months. Obi challenges that outcome as procedurally and substantively unreasonable. We affirm.

Posted by: Azya Thornton on Mar 13, 2025

KAREN NELSON MOORE, Circuit Judge. This § 1983 case concerns alleged constitutional violations in the investigation and prosecution of George Clark and Kevin Harrington. Clark and Harrington spent nearly two decades in prison before the Wayne County Prosecution Integrity Unit determined that they did not receive a fair trial because their murder convictions were secured based on the testimony of a singular eyewitness, who claimed she had been coerced to lie by detectives. Following dismissal of the charges and Clark’s and Harrington’s releases from prison, the men sued those detectives for violating their constitutional rights. After discovery, the district court granted in part and denied in part the detectives’ motion for summary judgment based on qualified immunity. Specifically, the district court denied qualified immunity on the men’s claims that the detectives fabricated the statement of the eyewitness, facilitated their prosecution without probable cause, and violated the Brady rule by withholding evidence that detectives threatened and offered benefits to key witnesses. The detectives filed an interlocutory appeal on the denial of qualified immunity. For the following reasons, we AFFIRM the district court’s denial of qualified immunity and REMAND for trial on the merits.

Posted by: Azya Thornton on Mar 13, 2025

A Maury County jury convicted Destiny Diamond Baxter and Anthony Wayne Sheffield of first degree premeditated murder, attempted first degree murder, especially aggravated robbery, two counts of felony murder, and abuse of a corpse. Defendant Sheffield was also convicted of possessing a firearm with a prior conviction for a crime of violence and employing a firearm during the commission of a dangerous felony. The jury determined that both Defendants should serve life in prison without the possibility of parole for the homicide offenses. As for the remaining convictions, the trial court sentenced Defendant Baxter to an additional twenty-two years and sentenced Defendant Sheffield to a further thirty-five years. On appeal, both Defendants challenge whether the evidence is legally sufficient to support their convictions. Defendant Sheffield also argues that the trial court erred in denying his motion to sever the Defendants’ cases and admitting photographs of the homicide victim into evidence during the jury’s sentencing phase. Further, Defendant Sheffield argues that the trial court improperly sentenced him for the other convictions by failing to consider the risk and needs assessment, miscalculating the range, and imposing consecutive sentences beyond his life term. Upon our review, we conclude that a harmless error exists in failing to issue a limiting instruction as requested by Defendant Sheffield, and we also remand the judgments for correction of clerical errors. However, we respectfully affirm the judgments of the trial court in all other respects.

Posted by: Azya Thornton on Mar 13, 2025

Defendant pled guilty in Williamson County to aggravated vehicular assault and three DUI counts. The trial court sentenced Defendant to six years in confinement. Defendant argues on appeal that her sentence is excessive and the trial court abused its discretion in denying alternative sentencing. After reviewing the record, the parties’ briefs, the applicable law, and oral arguments, we affirm the judgments of the trial court but remand for entry of corrected judgment forms as detailed in this opinion.

Posted by: Azya Thornton on Mar 13, 2025

We do not reach the substantive issues because the trial court failed to make sufficient findings as required by Tennessee Rule of Civil Procedure 52.01. Vacated and remanded.

Posted by: Stacey Shrader Joslin on Mar 13, 2025

A federal judge has temporarily blocked President Donald Trump’s administration from enforcing portions of an executive order designed to punish the law firm of Perkins Coie. The Associated Press reports that U.S. District Judge Beryl Howell granted a temporary restraining order sought by the firm one day after it filed suit over the executive order. The judge said the executive order sends a chilling message that lawyers can be punished for representing clients or advancing views unfavorable to the government. Under the ruling, the government may not enforce portions of the order blocking the firm from seeking government contracts for its clients and banning firm employees from federal buildings.

Posted by: Azya Thornton on Mar 13, 2025

Rhonda L. ("Mother") filed a petition in the Juvenile Court for the City of Bristol ("the Juvenile Court") to modify a parenting plan granting Mark K. ("Father") sole custody of Kendin L. ("the Child") and Mother at least four days of parenting time each month.' Father filed a motion for injunctive relief seeking the suspension of Mother's parenting time based upon Mother's persistent inappropriate behavior and psychological evaluation results. The Juvenile Court entered an ex parte order granting the motion for injunctive relief. After trial, the Juvenile Court dismissed Mother's petition for her failure ot prosecute and ordered that the suspension of Mother's parenting time remain in full effect until Mother engaged in therapy and treatment for her personality disorder. Mother appealed. Discerning no reversible error, we affirm.

Posted by: Azya Thornton on Mar 13, 2025

This appeal concerns termination of parental rights. The Tennessee Department of Children’s Services (“DCS”) filed a petition in the Juvenile Court for Humphreys County (“the Juvenile Court”) seeking to terminate the parental rights of Tabitha P. (“Mother”) and Cody T. (“Father”) to their minor child Gabriel T. (“the Child”). After a hearing, the Juvenile Court entered an order terminating Mother’s and Father’s parental rights on several grounds. Mother and Father appeal, arguing mainly that DCS failed to assist or communicate with them. The Juvenile Court determined that Mother and Father were not credible witnesses, a determination we leave undisturbed. We find that each ground for termination found by the Juvenile Court was proven by clear and convincing evidence. We find further by clear and convincing evidence, as did the Juvenile Court, that termination of Mother’s and Father’s parental rights is in the Child’s best interest. We affirm.

Posted by: Azya Thornton on Mar 13, 2025

This is an appeal of a denial of unemployment benefits. The issue presented is whether, under Tennessee’s unemployment statutes, an employee who gives her employer notice of her resignation as of a certain date and is terminated by the employer prior to the effective resignation date is disqualified from receiving unemployment benefits on the ground that the employee voluntarily quit. The trial court affirmed the agency’s decision denying benefits. Based upon the plain language of the relevant statutory provision, we conclude that the employee’s actions do not constitute a voluntary decision to quit. Therefore, we reverse the trial court’s decision.


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