This appeal involves the termination of a mother’s parental rights to one of her five children. After a five-day termination trial, the trial court found by clear and convincing evidence that two grounds for termination were proven and that termination was in the best interest of the child. We vacate one ground for termination but otherwise affirm the termination of parental rights.

Suspended Rutherford County lawyer Jared Michael Streich has been arrested on charges he violated his bond conditions when he visited the apartment of his girlfriend Miranda Gray. During the visit, Streich called police and reported that Gray was unresponsive. After arriving, police confirmed she was dead. An autopsy revealed she had been strangled. Streich previously had faced charges of aggravated assault against Gray, which led to the bond condition that he stay away from her apartment complex. Most of the previous charges were dropped and police said that Gray repeatedly declined their offers of counseling, orders of protection, prosecution and shelter services. Streich was suspended by the Tennessee Supreme Court in June for failing to communicate with clients, expedite clients' litigation, act competently and return client property. The court also found that he charged unreasonable fees and provided false information to the Board of Professional Responsibility. The Tennessean reports on the case.

A three-judge panel of the Tennessee Court of Appeals ruled on Aug. 15 that certain inmates facing life sentences can be released early for good behavior. The unanimous decision applies to people sentenced for crimes committed before July 1, 1995, or for crimes committed as a juvenile, according to The Tennessean. It will not apply to those sentenced to life without parole. The decision came in the case of Howard Aktins. David Esquivel, attorney for Atkins, said if the ruling stands, it means dozens or hundreds of people sentenced to life should have already been released from state custody. The Tennessee Attorney General’s Office, which could appeal the decision, says it is "still reviewing next steps." In Tennessee, a life sentence is considered to be 60 years. The appeals court estimated that under the Department of Correction’s good time calculation formula, inmates could shave off about 20 years from their sentences.

The man accused of organizing the murder of Memphis rapper Young Dolph in 2021 has been found not guilty, the Daily Memphian reports. A Memphis jury acquitted Hernandez Govan of charges of first-degree murder and conspiracy to commit first-degree murder today after three hours of deliberation. Prosecutors alleged Govan hired the two men who shot the rapper and then worked with them to secure payment for the killing.

Save the date for TBA’s 2025 Environmental Law Forum, set for Dec. 5 in Nashville. The program will run from 10 a.m. to 3:30 p.m. CST and will include lunch. This staple for Tennessee lawyers and environmental professionals will feature timely topics relevant to the practice area. Environmental Law Section members save on registration costs. Not a section member? Get started here. Stay tuned for more details about speakers and topics coming soon.

Lawyers for Kilmar Abrego Garcia and the U.S. Attorney’s Office for Middle Tennessee have agreed that Abrego Garcia can be released from custody tomorrow, the Nashville Banner reports. A flurry of filings on Tuesday and Wednesday of this week asked District Court Judge Waverly Crenshaw to release him on Friday. Crenshaw had issued a stay of his release order until Friday due to uncertainty about whether Immigration and Customs Enforcement (ICE) would attempt to detain and deport him again. But after a federal judge in Maryland barred ICE from using a detainer warrant to grab him upon release, both sides agreed to the release. Abrego Garcia’s attorneys also have asked Crenshaw to order ICE to allow him to have access to legal counsel in the event he is detained. The defendant is facing human smuggling charges in Nashville stemming from a 2022 traffic stop.

This appeal involves a petition to terminate the parental rights of a father to his young daughter. The trial court found that the ground of failure to manifest an ability or willingness to assume custody of the child had been proven by clear and convincing evidence and that termination of parental rights was in the best interest of the child. The father appeals. We affirm.

JULIA SMITH GIBBONS, Circuit Judge. Plaintiff Riccy Enriquez-Perdomo entered the United States illegally as a child. She was initially ordered to be deported, but later benefited from Deferred Action for Childhood Arrivals (“DACA”), which makes her order of removal non-enforceable. Prior to the immediate events, which gave rise to this lawsuit, Enriquez-Perdomo was a well-known visitor at a United States Immigration and Customs Enforcement (“ICE”) facility in Louisville, Kentucky where she frequently went to post bond for those held in custody. One day when Enriquez-Perdomo visited the ICE office in Louisville, she was suddenly detained by several ICE agents without a warrant or probable cause, despite her DACA status. Enriquez-Perdomo was then repeatedly moved to different locations across the country until she was finally released eight days later. After her release, Enriquez-Perdomo sued the ICE agents who detained her, alleging violations of the First, Fourth, and Fifth Amendments, relying on the Supreme Court case of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics to establish an implied federal cause of action. 403 U.S. 388 (1971). After a previous appeal, her First Amendment claims were dismissed. Upon remand, the district court then granted summary judgment to defendants, reasoning that all Enriquez-Perdomo’s Fourth and Fifth Amendment claims were invalid extensions of Bivens. Enriquez-Perdomo appealed. We now affirm the decision of the district court.

NALBANDIAN, Circuit Judge. Sometimes family members don’t make the best business partners. And sometimes closely held corporations don’t observe corporate formalities. Combine them and you’ll likely get a mess—which is what this case is.

We find that because the share transfer was not a resignation, and because Tarter Industries never took a formal act to reconstitute the board, the third generation was the board and its officers at the time of the special meeting. As a result, the meeting was validly called, the board had a quorum, and a majority of the directors voted to allow Tarter Industries to sue. As a result, the direct suit by Tarter Industries can proceed.

The Defendant, Jason A. McCain, pled guilty in the Henry County Circuit Court to reckless endangerment with a deadly weapon, a Class E felony. After a sentencing hearing, the trial court sentenced him as a Range III, persistent offender to six years in confinement. On appeal, the Defendant contends that the trial court should have sentenced him as a Range I, standard offender because the State did not file its notice of intent to seek enhancement punishment pursuant to Tennessee Code Annotated section 40-35-202(a) until the day of his sentencing hearing and that his six-year sentence is excessive. Based upon the oral arguments, the record, and the parties’ briefs, we affirm the judgment of the trial court.