The Supreme Court of Tennessee has temporarily suspended Matthew Lee Harris from the practice of law after finding that Harris was substantially non-compliant with his Tennessee Lawyer Assistance Program Monitoring Agreement. Harris is immediately precluded from accepting any new cases and must cease representing existing clients by May 17. The suspension will remain in effect until dissolution or modification by the court. The court also approved a motion to file documents in the case under seal.

Question 1: Do constables have arrest powers throughout the entire State of Tennessee?

Opinion 1: No. Constables cannot exercise governmental power to make arrests throughout the entire State of Tennessee.

Question 2: If a constable is tasked with serving process outside the constable’s county, and the constable observes a crime taking place outside the constable’s county, does the constable have authority to make the arrest?

Opinion 2: The scenario described in the question cannot arise. Constables lack authority to serve process outside their county.

Question 3: If a constable does not act to “cause the peace of the state to be kept [and] . . . arrest all persons that go in . . . sight armed offensively” or to “apprehend all felons, rioters, or persons riotously assembled,” would that violate the constable’s oath of office?

Opinion 3: It depends. Constables cannot violate the oath set out in Tenn. Code Ann. § 8-10-108(b) if they lack law enforcement powers or if their failure to act occurs outside their county.

The Defendant, Malik DeWayne Hardin, appeals the denial of his motion for resentencing for his guilty-pleaded conviction of possession with the intent to sell less than .5 grams of cocaine in a drug free school zone, which resulted in a sentence of twelve years at 100% as a Range II offender. The Defendant asserts that the trial court issued a fundamentally illegal ruling and palpably abused its discretion by comparing the sentence the Defendant received pursuant to his negotiated plea agreement to the sentence he faced if convicted of the greater charged offense and concluding that he would not receive a lesser sentence under the 2022 amendment to the Drug-Free School Zone Act. The Defendant therefore requests that this court, in the interest of justice, convert his improperly filed Rule 3 appeal into a common law writ of certiorari and reverse the ruling of the trial court. Because the Defendant has not shown that his case warrants review pursuant to a writ of certiorari, we dismiss the appeal.

The U.S. Justice Department (DOJ) is planning to sue Live Nation on antitrust grounds, Axios reports. The ticketing and live event company has faced intense scrutiny from lawmakers and consumer advocacy groups over botched ticket sales for Taylor Swift's "Eras Tour" in late 2022. Live Nation acquired Ticketmaster in 2010. At that time, the DOJ did not attempt to block the deal, but it barred the company from pressuring concert venues to use its ticketing software. The 10-year consent decree was extended for more than five years in 2020.

DAVIS, Circuit Judge. A jury convicted Katrina Robinson, founder and director of The Healthcare Institute (“THI”), of four counts of wire fraud for actions she took in administering a federal grant the organization received from 2015–2019. Robinson filed a post-verdict motion for a judgment of acquittal (“JOA”) on all four counts. The district court granted the motion as to two of the counts. In these consolidated appeals, the government challenges the court’s grant of JOA on one of those counts, and Robinson appeals the denial of JOA on the remaining two counts. Robinson also appeals the district court’s denial of her oral motion for mistrial with prejudice and her motion for a new trial. For the reasons that follow, we affirm in part, reverse in part, and remand for further proceedings consistent with this decision.

The bar associations of Hamblen, Hawkins and Greene counties will host a meet and greet for newly confirmed Tennessee Supreme Court Justice Mary Wagner. The event will take place April 26 from 5-8 p.m. EDT at Morristown Landing, 4355 Durham Landing, Morristown 37814. Refreshments will be provided. RSVP here, or direct questions to Lauren Carroll at 423-586-5291 or Mark Stapleton at 423-921-9100. Wagner, who currently serves on the Shelby County Circuit Court, was confirmed by the Tennessee General Assembly on March 11. She will join the Supreme Court after Justice Roger A. Page retires on Aug. 31.

CLAY, Circuit Judge. In 2017, Plaintiff Euna McGruder sued Defendant Metropolitan Government of Nashville and Davidson County (“Metro Nashville”) in United States District Court for retaliation under Title VII, 42 U.S.C. § 2000, et seq. In 2021, a jury awarded McGruder $260,000 for her claim, and the district court ordered Metro Nashville to reinstate her to her previous position. Metro Nashville appeals the district court’s reinstatement order and argues that the entirety of McGruder’s claims—including the jury award—should be barred by judicial estoppel due to her failure to disclose her cause of action against Metro Nashville when she filed for Chapter 7 bankruptcy in 2018. However, this Court lacks jurisdiction to consider Metro Nashville’s judicial estoppel claims as applied to non-final, non-appealable orders that are not before this Court. And the district court did not abuse its discretion in ordering McGruder’s reinstatement, which, as an equitable remedy, is not barred by judicial estoppel. For the reasons set forth below, we AFFIRM the district court’s reinstatement order and otherwise DISMISS Metro Nashville’s appeal for lack of jurisdiction.

PER CURIAM. An administrative law judge denied Keeley Hamilton’s applications for disability insurance benefits and supplemental security income because, despite her physical impairments, she could still work in two occupations. On appeal, Hamilton relies on Ninth Circuit caselaw to seek a categorical rule that would treat her as disabled unless she could work in at least three occupations. We disagree with the Ninth Circuit’s rule. So we affirm the district court’s decision upholding the Social Security Administration’s denial of benefits to Hamilton.

KAREN NELSON MOORE, Circuit Judge. At the conclusion of a jury trial, Joshua Aldridge was found guilty of conspiracy to sex traffic an adult by force, threats of force, fraud, or coercion, among other charges. Thereafter, the district court sentenced him to 324 months’ imprisonment. On appeal, Aldridge challenges the district court’s denial of his Rule 29 motion and the district court’s application of two sentencing enhancements. For the reasons explained below, we AFFIRM the district court.

Plaintiff alleged that actions of defendant tow truck driver led to John Doe driving into plaintiff’s vehicle and causing injury. Towing company and driver moved for summary judgment based on the lack of evidence as to the cause of John Doe’s actions. The trial court agreed, granting summary judgment for lack of evidence that towing company or driver was the cause in fact of plaintiff’s injury. Discerning no error, we affirm.