Federal sentencing dates for two former Memphis police officers charged in the 2023 death of Tyre Nichols have been canceled, the Daily Memphian reports. Emmitt Martin and Desmond Mills Jr., who both pleaded guilty to their roles in Nichols’ death, were scheduled to be sentenced Dec. 18 and Dec. 19, respectively. Prosecutors have recommended 40 years for Martin and 15 years for Mills. It is unclear why Martin’s sentencing date was canceled according to the paper. Blake Ballin, Mills’ attorney, argued in a request to move Mills’ sentencing that it should be postponed while the appeals process plays out for his and Martin’s three co-defendants. New dates have not yet been set for either defendant.

The TBA will host the 2026 Construction Law Forum on Jan. 23, 2026, at the Tennessee Bankers Association’s Bradley L. Barrett Training Center in Nashville. The full-day continuing legal education program, offering 6.5 hours of CLE credit, will offer two learning tracks. The first will offer introductory sessions in the morning covering lien rights, case law updates and common construction law mistakes. The second will focus on advanced sessions in the afternoon on the Prompt Pay Act, delay claims, ethics and artificial intelligence in construction law. Participants may register for morning, afternoon or full-day sessions, with programming designed to benefit both new and seasoned construction law practitioners. For more information and to register, visit the TBA website.

The TBA Mentoring Committee, in collaboration with the TBA Young Lawyers Division, will hold a special event — "Developing Lawyers, Developing Leaders: A CLE on Mentorship and Professional Excellence" — on Jan. 30, 2026, at Belmont University College of Law's Baskin Center. Make plans now to join TBA President Heidi Barcus; Marshall County General Sessions Court Judge Lee Bussart; University of Tennessee Winston College of Law professor Joan Heminway; Amy Schmisseur, chair of Belmont University's Department of Communication Studies; Joseph Hubbard of Polsinelli; and Toyin Edogun of Bass Berry & Sims as they explore topics of mentorship, leadership and communication across one's legal career. The day of "Mocktails and Mentorship" will include lunch and three hours of CLE credit, followed by a networking event and the opportunity to mix mocktails together. Because good conversations are meant to be shared, lawyers who register for this course are invited to bring a colleague with them at no additional cost.

The Tennessee Supreme Court on Nov. 21 suspended Maury County lawyer James Michael Marshall from the practice of law for five years, with two years to be served on active suspension and the remainder on probation. The court found that while representing a client, Marshall submitted a factually inaccurate pleading, then failed to correct the error and failed to reasonably communicate with his client regarding the error. Marshall entered a conditional guilty plea and acknowledged his conduct violated Tennessee Rules of Professional Conduct, 1.1, 1.3, 1.4, 3.2, 8.1(b) and 8.4(a).

JOHN K. BUSH, Circuit Judge. This appeal presents a question of first impression: Does a private cause of action for retaliation exist in § 504 of the Rehabilitation Act, codified at 29 U.S.C. § 794? For at least the last 25 years, we have assumed that it does, often analyzing Rehabilitation Act retaliation claims based on precedent interpreting Title VII of the Civil Rights Act or the Americans with Disabilities Act (ADA). Those statutes, unlike the Rehabilitation Act, have express anti-retaliation provisions. But we have never addressed—nor seemingly had reason to address—whether, and if so where, a retaliation cause of action lies in § 504 of the Rehabilitation Act. We are now faced with that question. Porter Smith sued the Michigan Department of Corrections (MDOC) and the State of Michigan under § 504 for (1) failing to provide him with a reasonable accommodation for his disability, and (2) retaliating against him for making an accommodation request and challenging its denial through legal action. The district court granted summary judgment to Defendants on the failure-to-accommodate claim, but the retaliation claim proceeded to trial. The jury found for Defendants. On appeal, Smith brings a handful of challenges stemming from the trial itself, one of which begs the question before us. Most relevantly, he argues that the district court erred as a matter of law when it instructed the jury that the causation standard for a retaliation claim under the Act was “sole causation.” As explained below, we hold that § 504 of the Rehabilitation Act does not provide a cause of action for retaliation. Based on this conclusion and for other reasons, we AFFIRM the district court’s judgment.

On Nov. 21, the Tennessee Supreme Court suspended Davidson County lawyer Robert Joseph Turner from the practice of law for one year, with 30 days to be served on active suspension and the remainder on probation subject to Turner engaging a practice monitor. Turner was retained to represent a client in a civil matter. During the pending litigation, at least five separate associates employed by Turner were assigned to handle the litigation, although he remained counsel of record. Over a four year period, Turner, or an associate assigned to the matter who Turner was supervising, failed to appear for hearings on multiple occasions, missed multiple deadlines and failed to comply with orders to contact the court. In dismissing the matter, the trial court cited Turner’s failure to properly represent his client and comply with court orders. Turner agreed to a conditional guilty plea acknowledging his conduct violated Tennessee Rules of Professional 1.3 and 5.1.

KAREN NELSON MOORE, Circuit Judge. Arsen Sarkisov is a citizen of Russia who has lived in the United States for at least two decades without legal status. Since 2013, he has been subject to a final order of removal. Several years ago, Sarkisov filed a self-petition under the Violence Against Women Act (“VAWA”) alleging that his former U.S.-citizen spouse subjected him to physical and emotional abuse. After the petition was granted, Sarkisov moved to reopen his immigration proceedings under a special rule for VAWA petitioners. To satisfy the rule, the VAWA petitioner must demonstrate “extraordinary circumstances or extreme hardship to the alien’s child.” The Attorney General, through her designee the Board of Immigration Appeals (“BIA”), concluded that Sarkisov did not meet that standard. Sarkisov petitioned for review. As a matter of first impression, we conclude that we have jurisdiction to review the BIA’s determination that Sarkisov did not demonstrate extraordinary circumstances. But because the BIA’s determination was not erroneous, we DENY the petition for review.

JULIA SMITH GIBBONS, Circuit Judge. The Immigration and Nationality Act (“INA”) allows the Attorney General to cancel the deportation of an otherwise deportable noncitizen if that noncitizen establishes four preconditions to relief. Singh v. Rosen, 984 F.3d 1142, 1147 (6th Cir. 2021); see also 8 U.S.C. § 1229b(b)(1). The four preconditions to relief are met if the noncitizen demonstrates: (1) continuous physical presence for a minimum of 10 years prior to the cancellation application; (2) he has been a person of “good moral character” during that period; (3) he has no convictions of a disqualifying offense; and (4) he has established that “removal would result in exceptional and extremely unusual hardship to the [noncitizen’s] spouse, parent, or child” who is a U.S. citizen or lawfully admitted permanent resident. 8 U.S.C. §§ 1229b(b)(1)(A)-(D). The INA defines “child” as “an unmarried person under twenty-one years of age[.]” Id. § 1101(b)(1). An immigration judge (“IJ”) granted Petitioner Roderico Filadelfo Perez-Perez cancellation of removal under § 1229b(b)(1)(D) in 2020, when his youngest daughter and qualifying “child,” Ady Perez-Velasquez, was seventeen years old. The government appealed, but the Board of Immigration Appeals (“BIA”) did not resolve the case until 2025, at which point it determined that Ady was over twenty-one and therefore no longer a qualifying “child” under the INA. As a result, the BIA vacated Perez-Perez’s cancellation of removal and ordered him removed to Guatemala. Because we now hold that the correct time to ascertain the age of a qualifying “child” under § 1229b(b)(1)(D) on an application for cancellation of removal is when the IJ issues its decision, we grant Perez-Perez’s petition for review and reverse the decision of the BIA.

LARSEN, Circuit Judge. A Michigan jury convicted Michon Houston of first-degree murder, possession of a firearm by a felon, and felony firearm. Claiming to possess new evidence showing ineffective assistance of counsel, Houston petitions for habeas relief—for the second time. The district court dismissed the petition for failing to satisfy the gate-keeping requirements of 28 U.S.C. § 2244(b)(2)(B) and for untimeliness. Because Houston satisfies neither the gate-keeping nor equitable-tolling requirements, we AFFIRM.

In 2006, the Defendant, Joshua Lee Shaw, pleaded guilty to attempted possession of a Schedule II substance with intent to deliver, a Class C felony, and simple possession of a Schedule VI substance, a Class A misdemeanor. The trial court sentenced him to four years of supervised probation. He violated his probation by testing positive for methamphetamine, amphetamine, and marijuana. The trial court ordered the Defendant’s punishment for the violation to be for “time served” and returned him to probation. The Defendant successfully completed the remainder of his probation. In 2024, the Defendant filed a petition to expunge his record of his two offenses pursuant to Tennessee Code Annotated section 40-32-101(k). After a hearing, the trial court declined his request. The Defendant appeals, contending the trial court erred. We conclude that the Defendant does not meet the plain language requirements of an “eligible petitioner” in Tennessee Code Annotated section 40-32-101(k), and thus we affirm the trial court’s judgment.