This is an accelerated interlocutory appeal as of right pursuant to Tennessee Supreme Court Rule 10B § 2.02 from the trial court’s denial of a motion for recusal. We have determined that the petition must be summarily dismissed due to substantive failures to comply with Rule 10B. Accordingly, the appeal is dismissed.

The parties sought a divorce from one another and specifically contested who should be their child’s primary residential parent. After a three-day trial, the General Sessions Court for Roane County (“the Trial Court”) entered a final decree of divorce and designated the mother as the child’s primary residential parent. The father appealed. Finding that the Trial Court’s judgment lacked sufficient findings of fact and consideration of the best interest factors codified in Tenn. Code Ann. § 36-6-106, we vacate the Trial Court’s custody determination and remand this cause for the Trial Court to provide written findings of facts and conclusions of law, demonstrating its consideration of the best interest factors.

The University of Tennessee Winston College of Law is seeking to hire a director of externships to begin no later than Aug. 1, 2026. The faculty-level position will include responsibility for judicial, prosecution and public defender externships, field placements, and the semester in residence program. Applications should be submitted online no later than Jan. 9, 2026. View the full job description or apply online. For questions, please contact professors Paula Schaefer and Danny Schaffzin, co-chairs of the Externship Director Search Committee.

This is a legal malpractice action that arises from alleged acts or omissions committed by attorney Steven L. Lefkovitz of Lefkovitz & Lefkovitz, PLLC, (“Defendant”) while representing Julie Buhler in a real estate dispute with Richard and Ellen Davis (“Sellers”) under an installment sales contract. The trial court summarily dismissed the legal malpractice action on the ground that two essential elements of a legal malpractice claim were not proven, specifically that “Plaintiff has failed to prove that Mr. Lefkovitz’s conduct was the cause-in-fact of her damages,” and “Plaintiff has not shown that Mr. Lefkovitz’s conduct was the proximate cause of her damages.” This appeal followed. We affirm.

A lawsuit filed last summer challenging a new state law — which eliminated consideration of a defendant’s ability to pay from judges’ bail decisions — has been certified as a class action, the Daily Memphian reports. The suit, filed by advocacy group Just City, now represents thousands of defendants who have been incarcerated in Memphis since the law took effect in May 2024. U.S. District Judge Thomas Parker said he granted the class certification because it met the requirements to do so under federal law, including having the amount of defendants required to become a class. The case is set to go to trial Feb. 23, 2026.

The Tennessee Comptroller’s Office has found that Weakley County Circuit Court Clerk Courtney McMinn improperly signed petitions to expunge criminal records for someone who was not eligible for expungement under state law. The office found that McMinn prepared four petitions for a person convicted of forgery in Weakley, Obion, Henry and Carroll counties and sent the petitions to court clerks in those counties. She signed the individual’s name on all four petitions and did not disclose the multiple convictions to the other clerks. Expungements ultimately were approved in Weakley and Carroll counties, but since have been reversed. The process in other counties was halted once the situation became known. The comptroller’s report was released on Dec. 8, six days after McMinn submitted notice of her resignation effective on Dec. 31, according to the Rogersville Review.

Lawrenceburg lawyer Charles W. “Charlie” Holt Jr. died Dec. 10 after a full day of work, according to his law firm. He was 74. Holt earned his law degree from the University of Tennessee (now Winston) College of Law in 1976 and began his legal career in Smyrna. He soon moved back home to Lawrenceburg and began practicing with William E. “Bill” Boston in the firm now known as Boston, Holt & Durham. In addition to nearly five decades of private practice, Hold also served as county attorney for Lawrence County for more than 30 years. He was an active member of the Lawrence County and Tennessee Bar associations and was a fellow of the Tennessee Bar Foundation. Visitation will be held Saturday from 11 a.m. to 2 p.m. CST with services immediately following. Arrangements are being handled by Neal Funeral Home.

Former Tennessee House Majority Leader Gerald McCormick has died at age 63 after a battle with amyotrophic lateral sclerosis, also known as Lou Gehrig's disease or ALS. A Chattanooga-area Republican, McCormick served seven terms in the state House of Representatives beginning in 2004. He was named chair of the Budget Subcommittee and later as House Majority Leader. Following his retirement, McCormick joined the Ingram Group to pursue a lobbying career. The Tennessean has more on his life, while Chattanoogan.com has reaction from his colleagues.

U.S. District Judge Paula Xinis of Maryland has ordered the immediate release of Kilmar Abrego Garcia from an ICE facility in Pennsylvania, Reuters reports. Xinis found that ongoing detention appears to be “constitutionally infirm” because no U.S. immigration judge has ordered his removal from the country. The AP reports he was released today. The Trump administration said it will appeal the ruling. Abrego Garcia also is awaiting trial in Nashville on charges of human smuggling. The judge in that case already ordered that he be released pending trial. Abrego Garcia has pleaded not guilty in that case, and his lawyers are seeking dismissal based on claims it is a vindictive and selective prosecution.

The TBA's Year End CLE Event includes a six-hour "Ultimate Ethics Package" designed to help Tennessee lawyers quickly earn dual credit. The 1-Click package includes an update from the Board of Professional Responsibility and courses on ethics in artificial intelligence, attorney wellness, leadership and professional development. Check out the specific courses included on the TBA website. Looking for something else? TBA also has six, eight, 10, 12 and 15-hour packages based on specific topics or practice areas, live webcasts and on-demand video all month long. Explore all the Year End options to complete your CLE requirement by Dec. 31.