This week's TBA Legislative Updates podcast features TBA lobbyists Berkley Schwarz of Pier Strategies LLC and Brad Lampley and Ashley Harbin of Adams and Reese. This week, they discuss several key bills, including SB1052/HB1355, which amends Tenn. Code Ann. §36-1-102(45)(B) to clarify that a biological father who only provides token support does not qualify as a putative father; SB540/HB492, addressing custody determinations and failure to pay child support; SB541/HB906, related to the TBA probate study group’s legislation; SB394/HB569, regarding the selection of a settlement agent in real property transactions; and SB943/HB1255, which focuses on continuing education for judges handling child custody cases. The podcast also covers the Tennessee Administrative Office of the Courts' (AOC) plan for indigent representation on behalf of the Tennessee Supreme Court. Watch Director Michelle Long present the AOC’s budget request, including funding for a new Office of Indigent Conflicts and Civil Counsel, which would oversee the state’s indigent representation system. Her testimony begins at 1:31:04. Listeners can tune in to the podcast on the TBA website or directly through this link.

MURPHY, Circuit Judge. Misty Coleman alleges that she fell and broke her ankle after slipping on the wet shower floor of a county jail. This accident led Coleman to pursue constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county and many corrections officers and medical personnel. The district court dismissed all claims against all parties. Coleman’s appeal raises a mix of substantive and procedural questions. As for the substantive: Did Coleman adequately allege that the slippery shower violated the Due Process Clause? Did she adequately allege that a county policy or custom was behind her poor medical care? And may the county invoke state-law immunity from her negligence claim at the pleading stage? As for the procedural: When did Coleman’s claims accrue and start the running of the statute of limitations? Did her amended complaint (which named actual corrections officers and medical personnel) “relate back” to the date of her original complaint (which named “John Doe” and “Jane Doe” defendants) for statute-of-limitations purposes? And can Coleman rely on equitable tolling to delay the running of the limitations period? We agree with the district court on the answers to all six questions. We thus affirm its dismissal of Coleman’s complaint. In sum, Coleman identifies nothing in the relevant factual and legal sources—her complaint and Ohio law—that justifies her equitable-tolling request. She thus has not met her burden to show that she qualifies for this doctrine. See Saalim, 97 F.4th at 1012; Roach, 2022 WL 2211529, at *2. We affirm.

PER CURIAM. In 1995, a Kentucky jury convicted Garr Keith Hardin and Jeffrey Clark of murdering Rhonda Sue Warford. Robert Thurman, a forensic serologist, testified at their trial that a hair found at the crime scene was “similar” to a sample of Hardin’s hair. After Clark and Hardin spent over two decades in prison, DNA testing proved that this hair was not, in fact, Hardin’s. A state court thus vacated Hardin’s and Clark’s convictions. Clark and Hardin then brought this suit under 42 U.S.C. § 1983 against (among others) Thurman. In discovery, they obtained the “observation notes” that Thurman had written when examining the hairs. These notes suggested that the hair found at the scene might not have matched Hardin’s hair sample in various ways. Hardin claimed that Thurman’s failure to disclose the notes before trial violated his disclosure obligations under Brady v. Maryland, 373 U.S. 83 (1963). The district court denied Thurman’s qualified-immunity defense. On appeal, Thurman argues (1) that his notes were neither exculpatory nor material under Brady, and (2) that the law in the mid-1990s did not clearly establish that Brady’s duty of disclosure applied to scientists. Our precedent deprives us of jurisdiction over Thurman’s first argument. And it also dooms his second argument that Brady did not clearly apply to him. We thus affirm in part and dismiss in part for lack of jurisdiction.At day’s end, cases like Moldowan and Gregory bind us here. So I concur in the majority opinion. But I see room for debate over whether those decisions resolved these issues correctly.

The defendant, Davarious Montral Taylor, was convicted by a Tipton County Circuit Court jury of second-degree murder and sentenced to twenty-five years in the Tennessee Department of Correction. On appeal, the defendant challenges the sufficiency of the convicting evidence and the sentence imposed by the trial court. After review, we affirm the judgment of the trial court.

In 2023, the Defendant, Jeremy Allen Stephens, entered a guilty plea to two counts of aggravated child abuse. Subsequently, the Defendant filed a motion to withdraw his plea, which the trial court denied. At the subsequent sentencing hearing, the trial court imposed an effective sentence of fifty years. On appeal, the Defendant contends that his motion to withdraw his guilty plea should have been granted and that the trial court erred when it imposed consecutive sentences. After review, we affirm the trial court’s judgments.

The Defendant, Sergei Aleksandrovich Novikov, was convicted by a Davidson County Criminal Court jury of attempted second degree murder, a Class B felony, and aggravated assault, a Class C felony. The trial court merged the aggravated assault conviction into the attempted second degree murder conviction and sentenced the Defendant as a Range I, standard offender to ten years in the Tennessee Department of Correction. On appeal, the Defendant challenges the sufficiency of the evidence and argues that the trial court erred in ordering a sentence of confinement without making proper findings that the Defendant was not entitled to alternative sentencing. Based on our review, we affirm the judgments of the trial court.

The Petitioner, Clarence Willis Moore1, appeals the denial of his petition for post- conviction relief from his Class B felony drug convictions, arguing that he was denied the effective assistance of counsel due to trial counsel’s failure to review videotape evidence with him or to convey the State’s plea offer, and that the post-conviction court erred by concluding that the Petitioner was not a credible witness. Because the Petitioner’s claim that he was denied the effective assistance of counsel was previously determined by the trial court in the Petitioner’s motion for new trial, we conclude that the issue is waived. Accordingly, we affirm the denial of post-conviction relief.

A Madison County jury convicted the defendant, Sonny Edmund Hudson, Jr., of two counts of attempted first-degree murder and one count of especially aggravated robbery, for which he received an effective sentence of twenty-three years in confinement at 100%. On appeal, the defendant contends the evidence presented at trial was insufficient to support his conviction for the attempted first-degree murder of James Theus. After reviewing the record and considering the applicable law, we affirm the judgments of the trial court.

A Dickson County jury convicted the Defendant, Lamisha Lanea Haynes, of second degree murder, and the trial court sentenced the Defendant as a Range I offender to serve twenty years in the Tennessee Department of Correction. On appeal, the Defendant asserts: (1) the evidence is insufficient to sustain her conviction; (2) the trial court improperly excluded testimony about the victim’s prior gun use; (3) the trial court improperly instructed the jury on flight; and (4) her sentence is excessive. The Defendant also claims that the cumulative error of these issues warrants relief. After review, we affirm the trial court’s judgment.

The pro se Defendant, Marcus Fitts, attempts to appeal the Sumner County Criminal Court’s summary dismissal of his motion to remove the sexual offender registry requirement from his judgment of conviction for attempted aggravated sexual battery. Because the Defendant has no grounds to appeal the summary dismissal of his motion, we dismiss the appeal.