The Memphis Bar Association's Access to Justice Committee, together with the TBA Young Lawyers Division and other organizations, are hosting a Restorative Rights & Resource Fair on Nov. 22. Services to be offered include expungements, voter reinstatements, driver's license reinstatements and resume help. The event will take place at the Hickory Hill Community Center, 3910 Ridgeway Rd., Memphis 38115 from 9 a.m. to noon CST. Fill out this form to volunteer. See a flyer for more information.

TBA's Real Estate Law Section, in partnership with the Tennessee Land Title Association, will host its annual Hot Topics in Real Estate program virtually tomorrow, Nov. 7. This event is a staple for Tennessee dirt lawyers, designed to keep you on the cutting edge of developments in your practice. Topics will include a comprehensive legislative update, FinCEN, the new foreclosure law, ALTA 49 endorsements and wholesaling. Additionally, Jeff Lanier, a financial expert at Stewart Title, will provide a business and economic update titled "Rates, Resilience and the Road Ahead: Understanding the Economic Forces and Strategic Shifts Impacting Title Insurance." Don't miss this annual favorite!

The latest issue of the Tennessee Bar Journal is live online and full of articles of interest to lawyers across practice areas! In this issue's cover story, Nathan Drake, Amy Bryson Smith and Mary Lauren Teague of Belmont University College of Law look at three recent copyright decisions and how courts are analyzing the legitimacy of using copyrighted material without permission to train AI platforms. Brad Bald's feature focuses on the importance of change orders in construction projects and how to effectively manage them. And TBJ turns 60 this year! Heidi Barcus' President's Perspective column kicks off our celebration. Enjoy a retrospective timeline of the last six decades of the Journal. Our regular columns Crime & Punishment, History's Verdict and The Buddy System are inside, as well as a book review and information about running for TBA office in 2026. Look for the print version in mailboxes in the next few weeks!

NALBANDIAN, Circuit Judge. Damon Patterson murdered someone while on supervised release, so the district court revoked his supervised release and imposed a term of reimprisonment. Patterson raises procedural and substantive objections to his new sentence, but we find his challenges meritless and affirm.

READLER, Circuit Judge. After working as a shift supervisor at a Starbucks café for nearly three years, Hannah Whitbeck led a movement to organize a union there. Several months into that campaign, Starbucks fired her. In its termination letter, the company justified its decision with a seemingly innocuous explanation: Whitbeck left an employee alone in the café for roughly half an hour, without telling any supervisor or co-manager, in violation of company policy. Through the filing of an administrative complaint, the National Labor Relations Board challenged this explanation. In the Board’s view, Starbucks discharged Whitbeck due to her organizing activity, thereby committing an unfair labor practice in violation of § 8(a)(1), (3), and (4) of the National Labor Relations Act. An Administrative Law Judge agreed. Starbucks Corp., 372 NLRB No. 122, slip op. at 21, 2023 WL 5137739 (Aug. 9, 2023). The Board later affirmed that decision and expanded the statutory remedy, ordering Starbucks to compensate Whitbeck for any “direct or foreseeable pecuniary harms” suffered because of the anti-union discrimination against her. Id. at 4–5. We grant the Board’s petition for enforcement of its decision that Starbucks committed an unfair labor practice. But because the Board exceeded its statutory authority in awarding Whitbeck “direct or foreseeable” monetary damages, we vacate the remedy and remand.

THAPAR, Circuit Judge. A set of objectors to a class-action settlement are over eight months late in paying an $850,000 appeal bond. Instead of paying up, they moved to extend the time to appeal the bond order—one day late. Because they’re a day late, we can’t hear their reasons for being $850,000 short. We dismiss their appeal of the motion to extend for lack of jurisdiction, and we dismiss their appeals of the settlement for failure to pay the bond.

THAPAR, Circuit Judge. Police dispatcher Linda DeVooght sued her employer for gender discrimination. Just eleven days later, she became the subject of an Internal Affairs investigation, which ended in her termination. So she sued again—this time, alleging the City of Warren and its Police Commissioner unlawfully retaliated against her for suing them. The district court denied Commissioner William Dwyer qualified immunity. This interlocutory appeal followed. Federal courts can hear interlocutory appeals only in a narrow set of circumstances. Usually, that jurisdiction is limited to purely legal questions. Isolating the purely legal questions in this appeal, we affirm the district court’s denial of qualified immunity. Appellants also raise factual arguments about causation, which we dismiss for lack of appellate jurisdiction at this interlocutory stage.

SUTTON, Chief Judge. In 2016, Corning Place paid $6 million to buy the Garfield Building, an eleven-floor, nineteenth-century property in downtown Cleveland. Sixteen months later, it created an “Historic Preservation and Conservation Easement,” which would donate the right to modify the façade and to increase the Garfield’s height (by 34 floors) to a local charity. Corning Place claimed a $22 million tax deduction for that donation, nearly four times what it had paid for the building. The Internal Revenue Service disallowed the deduction and imposed penalties. It found that Corning Place claimed the deduction for the wrong year, substantially overvalued its worth, and failed to document key expenses. Corning Place challenged the disallowance and penalties in Tax Court. The Tax Court agreed with the IRS. We do too and affirm.

The Petitioner, Isaac McDonald, appeals from the Madison County Circuit Court’s denial of his petition for post-conviction relief, arguing that trial counsel rendered ineffective assistance by failing to adequately review or provide him copies of discovery materials, by failing to adequately explain the terms of his plea agreement, and by coercing him into pleading guilty. Discerning no error, we affirm.

The Petitioner, Steven Griffin, appeals from the Hardeman County Circuit Court’s summary dismissal of his second petition for writ of habeas corpus. On appeal, the Petitioner argues his sentence is illegal because the trial court failed to find he qualified as a dangerous offender and, accordingly, its imposition of partially consecutive sentences was improper. Discerning no error, we affirm.