Completing CLE requirements before Dec. 31 is now easier than ever with new packages from the TBA. The “CLE Made Easy Series” offers curated packages based on hours needed or special interest topics. Credit hour packages include 15, 12, 10 and eight-hour offerings. Topical options include 15 hours for solo and small practice lawyers, eight hours from the TBA’s 2025 Convention and six hours from the Young Lawyers Division’s Rookie Series. Looking for ethics hours? Two three-hour packages also are available. Don’t see what you are looking for in the new offerings? Check out the more than 100 on-demand programs and upcoming live programs in the TBA's online course catalog.

The Nashville Bar Association (NBA) has released the results of a member poll of applicants being considered to fill a vacancy on the 20th Judicial District Circuit Court. The candidates rated included Audrey L. Anderson, Bethany Peery Glandorf, Harold E. Rushton, Morgan E. Smith and John Ray Wilks. The vacancy on the third circuit is due to the retirement of Judge Phillip R. Robinson. The association reports that 251 responses were received by the deadline. See the poll results in a release from the NBA. The Trial Court Vacancy Commission is set to consider the candidates at a public hearing on Oct. 17.

A federal court should set aside a new $100,000 fee imposed on H-1B workers by the Trump administration, according to a lawsuit filed by a coalition of labor unions, health care providers, academic groups, religious organizations and individual visa holders. The plaintiffs are being represented by the Justice Action Center. According to Bloomberg Law, the suit claims that the fee violates the Immigration and Nationality Act and the Administrative Procedure Act. The Trump administration says the changes are needed to discourage business from “spamming the system and driving down American wages.” President Donald Trump signed a proclamation on Sept. 19 raising the fee. It later clarified the fee increase would apply only to new applicants. The Department of Homeland Security also recently announced it would look at overhauling the H-1B annual lottery process.

JANE B. STRANCH, Circuit Judge. Derek Riley was eligible for resentencing under Amendment 821 to the Sentencing Guidelines. His counsel and the Government stipulated to a recommended sentence, and the district court imposed that sentence. Riley then filed a motion for reconsideration, asserting that he was proceeding pro se in order to make clear that his counsel had agreed to the stipulation without his knowledge and against his wishes, and that a lower sentence was warranted. The district court denied the motion without reaching the merits on the basis that it had not been filed through counsel and therefore constituted improper hybrid representation. For the reasons that follow, we VACATE the district court’s judgment on Riley’s motion for reconsideration and REMAND for further proceedings.

JULIA SMITH GIBBONS, Circuit Judge. In this case, the district court certified a class of Tennesseans insured by State Farm Mutual Automobile Insurance Company (“State Farm”) who, after their cars were totaled, received a payout from State Farm that was calculated utilizing car valuation data generated by another company, Audatex. Named plaintiff-appellee Jessica Clippinger1 argues that the use of a particular cost adjustment as part of this methodology impermissibly reduced those valuations in breach of contract and Tennessee law. The district court certified a class made up of State Farm-insured Tennessee plaintiffs who received an “actual cash value” payout for the total loss of a car, where the payout was calculated by that methodology and decreased by application of the challenged adjustment. State Farm appealed class certification, and we granted review. We now affirm the district court’s certification of the class and remand for further proceedings.

KAREN NELSON MOORE, Circuit Judge. In a prior appeal, this court granted Petitioner-Appellant Malik Allah-U-Akbar a conditional writ of habeas corpus, “vacating [his] death sentence unless the State of Ohio conducts a new penalty-phase proceeding within 180 days of remand.” Jones v. Bradshaw, 46 F.4th 459, 489 (6th Cir. 2022). The state did not comply with the writ. The district court then converted this conditional writ to an unconditional writ. The unconditional writ ordered the state “to vacate the death sentence imposed by the Ashtabula County, Ohio, Court of Common Pleas . . . and unconditionally release Jones from custody no later than five business days from the date of entry of” the order entered on February 29, 2024. Jones v. Bradshaw, No. 1:03 CV 1192, 2024 WL 895153, at *11 (N.D. Ohio Feb. 29, 2024). The state did not fully comply with the unconditional writ until May 29, 2024, roughly ninety days after the unconditional writ was entered. In response, Allah-U-Akbar filed a motion for relief from the unconditional writ, and sought as a sanction for noncompliance an order barring the state from reprosecuting the death penalty. The district court denied this request on the merits. For the reasons that follow, although we agree with Allah-U-Akbar that we have jurisdiction over this appeal, we nevertheless AFFIRM the judgment of the district court.

This is the second appeal by a mother and a father of the termination of their parental rights. We have concluded that the juvenile court correctly determined that a ground for termination existed as to the father. Regarding Mother, we find that the court erred in its analysis finding a ground for termination. We also conclude that the court failed to make sufficient findings regarding the ground for termination and vacate this portion of the order and remand for further proceedings. We also conclude that the juvenile court did not make sufficient findings of fact in its best interests analysis regarding Father. Therefore, we also vacate this part of the order and remand the matter for the juvenile court to enter an order that makes sufficient findings.

Father appeals the trial court’s order changing his children’s surnames from his surname to another family name. Due to the deficiencies in Appellant’s brief, we do not address four of his stated issues. As to his final issue, because the appellate record contains no transcript or statement of the evidence as required by the Tennessee Rules of Appellate Procedure, we have no evidence to review. Accordingly, we must presume that the evidence presented at the final hearing supports the trial court’s conclusion that the name change was in the children’s best interests. We affirm.

Local prosecutors are "drowning" in prison crime cases committed inside Tennessee's largest prison, District Attorney General Jason Lawson told members of the state Senate on Oct. 1. According to Lawson’s testimony, his office has prosecuted more than 204 offenses since 2021 — including murder, attempted murder, rape, assault, possession of contraband and indecent exposure — despite insufficient resources and policies that prevent evidence gathering. But he also said that the crimes prosecuted represent a “dramatic underestimate” of the actual offenses committed. The long-troubled facility is run by private prison operator CoreCivic and is under investigation by the U.S. Department of Justice. Also at the hearing, Tennessee Corrections Commissioner Frank Strada told legislators that gang members incarcerated at Trousdale often bribe guards to bring contraband through security. The Tennessean has more on the story.

U.S. Attorney for the Western District of Tennessee Michael Dunavant was confirmed by the U.S. Senate on Oct. 7 by a vote of 51-47. The Daily Memphian reports that the vote came on a slate of 107 nominees, including 15 other U.S. attorney nominees, ambassadors and other appointed officials. President Donald Trump nominated Dunavant in July. Dunavant returns to the office after having served as U.S. attorney during Trump’s first term of office. He previously served as district attorney general for Tennessee's 25th Judicial District, which covers Tipton, Fayette, Hardeman, Lauderdale and McNairy counties. He replaces career prosecutor Joe Murphy, who has been the interim U.S. attorney since Reagan Fondren was removed. Fondren took over after Kevin Ritz stepped down following his appointment to the U.S. 6th Circuit Court of Appeals.