In this edition of Voices of the YLD, Morgan Hanna writes of the importance that servant leadership holds in her personal and professional life. Hanna practices insurance law in house as an associate general counsel. She earned her law degree from the University of Tennessee College of Law (now Winston College of Law) and her bachelor’s degree from Rhodes College. Hanna serves on the TBA YLD Board’s Long Range Planning Committee and as the Leadership and Law Academy Middle Tennessee chair. This summer, she finished her two-year term as District 7 representative on the board.

The TBA YLD will be visiting all six Tennessee law schools this fall for its annual meet and greet events. Members of the YLD Board will discuss the benefits of FREE TBA membership for law students and the many opportunities to get involved with the TBA while still in law school. They also will answer questions about entering and working in the legal field. In addition, members of the DLI Class of 2025 and the inaugural Rural Judicial Fellowship program have been invited to to speak about their experiences. There will be lunch and giveaways! All are welcome to attend: 

• Vanderbilt University Law School, Sept. 9 from 12-2 p.m. CDT
• Belmont University College of  Law, Sept. 10 from 12-1 p.m. CDT
• University of Tennessee Winston College of Law, Sept. 17 from 12-1 p.m. EDT
• Lincoln Memorial University Duncan School of Law, Sept. 18 from 12-1p.m. EDT
• Nashville School of Law, Sept. 25 from 5:15-6:15 p.m. CDT
• University of Memphis Cecil C. Humphreys School of Law, Oct. 9 from 12-1 p.m. CDT

Members of the TBA Young Lawyers Division (YLD) attended the American Bar Association (ABA) 2025 Annual Meeting in Toronto this weekend. President Alex McVeagh, Immediate Past President Sean Aiello, Vice President Darius Walker Jr., Middle Tennessee Governor Alix Rogers, Membership Committee Chair and Health and Wellness Coordinator Patrick Morrison and CLE Middle Coordinator Kristen Walker connected and networked with influential legal professionals from across the country. They were joined by 2023-2024 TBA YLD Board member Patrick Morris, who is speaker of the ABA YLD. The TBA YLD Newsletter was recognized at the meeting with an achievement award for outstanding activities and accomplishments during the 2024-2025 bar year. See photos from the event.

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The 2025 Southeast Complex Litigation Conference will be held Oct. 29 at the Tennessee Bankers Association in Nashville, offering updates on mass torts, class actions and whistleblower cases. National litigators will discuss emerging litigation involving medical devices, pharmaceutical drugs and consumer products, as well as best practices for identifying, prosecuting and defending complex cases. Session topics include class actions and multidistrict litigation basics, whistleblower claims under the False Claims Act and key trends in aggregate litigation. Speakers include Mark Chalos of Lieff, Cabraser, Heimann & Bernstein and Tricia Herzfeld of Herzfeld, Suetholz, Gastel, Leniski & Wall, with additional speakers and content to be announced in the coming weeks. For more details, to register and to stay updated, visit the TBA website.

READLER, Circuit Judge. Section 922(g)(3) of Title 18 prohibits unlawful drug users from possessing firearms. 18 U.S.C. § 922(g)(3). Echoing the sentiment that drug users in possession of firearms raise heightened safety concerns, the Sentencing Guidelines instruct district courts to increase a defendant’s base offense level in firearm possession cases if he is a “person described” in § 922(g)(3)—in other words, if he is an unlawful user of controlled substances and possesses firearms. U.S. Sent’g Guidelines Manual § 2K2.1(a)(4)(B) (U.S. Sent’g Comm’n 2024) (hereinafter Guidelines); id. cmt. n.3. In this case, Terrence Wayne VanOchten pleaded guilty to possessing three unregistered firearms (pipe bombs). Over VanOchten’s opposition, the district court increased his base offense level on the grounds that he is a “person described” in § 922(g)(3). Id. cmt. n.3. That leaves us to resolve the constitutional question at the heart of VanOchten’s objection: whether § 922(g)(3) may be enforced against him, consistent with the Second Amendment. We agree with the government that it can, and thus affirm the district court’s sentence.

RONALD LEE GILMAN, Circuit Judge. A jury found Dr. Ankita Singh guilty on six counts of healthcare fraud, in violation of 18 U.S.C. § 1347. On appeal, Singh argues that the district court committed three reversible errors. First, she argues that the court incorrectly instructed the jury on the meaning of the word “willfully” in the healthcare-fraud statute. She next contends that the court abused its discretion by excluding exculpatory statements made by Singh to an insurance-company investigator that reflected her then-existing state of mind. Finally, Singh argues that the court abused its discretion by allowing lay witnesses to testify that a provider must personally examine a patient in order to determine the medical necessity for certain prescribed equipment. We find merit in all three of Singh’s arguments. And because these errors were not harmless, we VACATE Singh’s convictions and REMAND for further proceedings consistent with this opinion.

CHAD A. READLER, Circuit Judge. After being fired from her job as a sales representative, Dorothy Bivens sued her employer, Zep, Inc., asserting claims under Title VII and Michigan law. According to Bivens, the company created a hostile work environment based on the actions of a company client. And when she complained about the client’s harassment, she adds, the company fired her in retaliation for those complaints. Alternatively, she claims, Zep fired her because she is black. The district court granted Zep summary judgment on all three claims. We affirm.

The Defendant, Christian Workman, appeals from the revocation of his probation, arguing the trial court improperly revoked his probation based upon his failure to pay court costs and supervision fees. The State concedes error, and after review, we agree. Accordingly, we reverse the judgment of the trial court and dismiss the revocation warrant.

The Defendant, Joshua Terelle Gaines, was convicted in the Davidson County Criminal Court of first degree felony murder, second degree murder, especially aggravated robbery, and being a felon in possession of a firearm after having been convicted of a felony drug offense and received an effective sentence of life plus five years in confinement. On appeal, the Defendant claims that the trial court erred by redacting his psychological expert’s report and by limiting the expert’s testimony. Based upon our review, we affirm the judgments of the trial court.