TBA's Adoption Law Section will present its annual forum next month on Sept. 19 in Nashville. The schedule is jam-packed with useful and practical sessions, including legislative updates and review with previous section chair Meredith Brasfield, as well as case law updates from the Department of Children's Services, and a judicial panel discussing best practices in contested hearings with judges from across the state. Make plans now to join us!

Federal Reserve (Fed) Chair Jerome Powell in a speech on Friday signaled interest rate cuts could be coming soon. Powell said while labor markets and the economy remain in good shape, tariff policies risk a spike in inflation that could make a cut counterproductive. This comes amid pressure from President Donald Trump, who has criticized Powell and demanded aggressive cuts from the Fed. The chair alluded to the dispute saying the Federal Open Market Committee (FOMC) will make decisions based solely on an assessment of the data and its implications for the economic outlook. Experts anticipate the FOMC to make an announcement at its Sept. 16-17 meeting. CNBC has more.

The Topgolf Estate Planning Tee-off will feature a session on the fundamentals of taxation for trusts and estates. Rob Malin of Pinnacle Financial Partners and Branch Howard of Brown Brothers Harriman will lead a discussion on income taxes and related issues encountered when administering these assets. Other topics at the tee-off include drafting tips for trusts, benefits available to individuals with disabilities and more. The package includes breakfast and lunch, plus two hours of Topgolf after the presentations. Learn more and register here.

There are many ways to get involved with the TBA Young Lawyers Division. Here are a few:

• The criminal case for the 45th Tennessee State High School Mock Trial Competition is being drafted right now and will be released in November. Volunteers will be needed at district competitions across the state in February and at the state competition March 20-21 in Nashville.
• Volunteer at TBA YLD clinics across the state.
• Contribute to the TBA YLD newsletter by submitting a piece for Voices of the YLD to Publications Chair Brian Mounce. 
• Have a topic idea for a CLE? Would you like to participate in a CLE? Contact Membership Chair Patrick Morrison.

The TBA YLD Rookie Series continues with a webcast on the role of federal magistrate judges on Dec. 3 at 12 p.m. CST. Make plans now to join U.S. Magistrate Judges Mike Dumitru, Debra Poplin and Cynthia Wyrick for a panel moderated by TBA YLD Board member and CLE Chair for East Tennessee Weslen Lakins. Watch for more information coming soon.

The TBA Young Lawyers Division (YLD) will host “The Rookie Series: Compassionate Lawyering” webcast on Aug. 27 from noon to 1 p.m. CDT. The program will introduce attorneys to the principles of trauma-informed legal practice and explore how lawyers can better serve clients — especially those from marginalized or vulnerable backgrounds — by incorporating empathy and awareness into their work. Mental health professionals will join the discussion to examine how legal systems can unintentionally retraumatize clients and offer strategies for compassionate advocacy across various practice areas. For more information and to register, visit the TBA website.

Do you want to read a Tennessee Bar Journal article from 30 years ago? Did you miss an issue of TBA Today or a section Connect newsletter? You can access the archives of all TBA publications online. Journal issues going back to 1965 are available as PDFs; TBJ Select, which was launched in 2020, can be viewed as an online publication; nearly 20 years of TBA Today issues are available for viewing; and section Connect newsletter archives are available on each section's homepage in the right hand column under "Group Menu." Log in to your MyTBA account for full access to all of these great publications.

COLE, Circuit Judge. Each year on his birthday, William Plott received a payment from Wilcac Life Insurance Company under Wilcac’s annuity contract with the Department of Health and Human Services (HHS). After Plott died two months before his twenty-ninth birthday, his estate sought one final payment from Wilcac. Wilcac refused, and Plott’s estate sued Wilcac and HHS. The district court concluded that HHS was a necessary and indispensable party under Federal Rule of Civil Procedure 19, but as HHS could not be joined without defeating the district court’s subject matter jurisdiction, the district court dismissed the case. Because the district court improperly applied Rule 19, we reverse and remand for further proceedings.

NALBANDIAN, Circuit Judge. Two suspicious packages, two weeks apart, passed through the Cleveland Postal Service distribution center in early 2021. United States postal inspectors flagged both for a possible connection to drug trafficking. After more research that added to their suspicion, inspectors called for a canine sniff of the packages. The dog, Ciga, alerted to both. Based on this evidence, a Postal Inspector applied for search warrants to open the packages and both revealed evidence of illicit activity. The investigation that followed led to the arrest and indictment of Jaavaid McCarley- Connin for his role in a drug-trafficking conspiracy. He moved to suppress the evidence from the package searches. He claimed he was entitled to an evidentiary hearing and extrinsic evidence to undermine Ciga’s reliability. The district court denied the motions, so McCarley- Connin pleaded guilty but reserved his right to challenge the trial court’s ruling on the suppression motion. Now, he presses on us the same theory that the district court denied below. First, he claims that Florida v. Harris, 568 U.S. 237 (2013) entitles him to an evidentiary hearing because he offered extrinsic evidence undermining Ciga’s reliability. And second, he claims that even without a hearing, Harris required the court to consider his extrinsic evidence; if he had, the court would have found the affidavit lacked probable cause. Because Harris does not reach as far as McCarley-Connin suggests, we AFFIRM the district court.

A Davidson County jury found the Defendant, Baeho Shin, guilty of especially aggravated kidnapping, aggravated sexual battery, and domestic assault, among other offenses. Thereafter, the trial court imposed an effective sentence of twenty-two years’ incarceration. On appeal, the Defendant contends that the trial court violated his constitutional right to confrontation. More specifically, he argues that the court prohibited him from cross- examining the victim about her potential interest in obtaining a U visa, which is a non- immigrant visa available to certain victims of crime. Although the trial court later allowed the Defendant to recall the victim and question her on the topic, he argues that the delayed timing of the examination rendered the remedy inadequate and prejudicial. Upon our review, we conclude that the trial court acted within its discretion in controlling the scope and timing of the cross-examination and that any possible error was harmless beyond a reasonable doubt. We respectfully affirm the judgments of the trial court.