RONALD LEE GILMAN, Circuit Judge. In August 2022, Congress passed the Inflation Reduction Act, which gave the Secretary of the U.S. Department of Health and Human Services (HHS) the ability to negotiate prices for drugs manufactured by companies that choose to sell to Medicare and Medicaid under the Drug Price Negotiation Program. The Dayton Area Chamber of Commerce (the Dayton Chamber), the Ohio Chamber of Commerce (the Ohio Chamber), the Michigan Chamber of Commerce (the Michigan Chamber), and the Chamber of Commerce of the United States of America (the U.S. Chamber) (collectively, Plaintiffs) sued HHS, the Centers for Medicare & Medicaid Services (CMS), and the agencies’ heads (collectively, the government) on behalf of their pharmaceutical-manufacturer members, challenging the constitutionality of the Drug Price Negotiation Program. Plaintiffs claimed that the Program amounted to the government’s attempt to “displace[] market forces and set[] prices on targeted products through central planning.” They based their challenge on the United States Constitution’s Due Process Clause, Excessive Fines Clause, and First Amendment. In addition, Plaintiffs contended that Congress exceeded its legislative powers. They requested both declaratory and injunctive relief. The government moved to dismiss the complaint on the basis that the Dayton Chamber lacked associational standing because the lawsuit was not germane to the Dayton Chamber’s purposes, making venue in the Southern District of Ohio improper. Agreeing with the government, the district court dismissed the case for improper venue. For the reasons set forth below, we AFFIRM the judgment of the district court.

DAVIS, Circuit Judge. Malcolm Hoyle pleaded guilty to being a felon in possession of a firearm and admitted that the conduct underlying that offense was a violation of a condition of his supervised release. In a joint sentencing hearing that covered both the substantive felon-in- possession charge and the follow-on supervised-release violation, the district court imposed 96 months’ imprisonment for the felon-in-possession offense and 24 months for the supervised- release violation, to be served consecutively. Hoyle claims three errors. First, he contends that he never knowingly and voluntarily waived his right to a revocation hearing for the supervised- release violation, so we should remand the case for such a hearing. Second, he argues that the district court erroneously applied the sentencing factors delineated in 18 U.S.C. § 3553(a) during his sentencing on the violation, and this misapplication of the factors led to a procedurally unreasonable sentence. Third, he asserts that his sentence on the substantive offense is also procedurally unreasonable, because the district court improperly calculated his sentencing guidelines when it erroneously gave career-offender treatment to two of his prior convictions. His first and third claims of error lack merit. But because the district court clearly considered inapplicable statutory factors in fashioning Hoyle’s sentence for the supervised-release violation, we AFFIRM IN PART, REVERSE IN PART, and REMAND for further proceedings.

JOHN K. BUSH, Circuit Judge. This case is about pension funds, actuaries, and the Employee Retirement Income Security Act (ERISA). But we can analogize it to a chat about a basketball game. Imagine asking a professional oddsmaker to give his best estimate of how many points the Louisville Cardinals will give up in their next game. And assume there are no extenuating circumstances. Last season, the Cardinals allowed 70 points on average, and they never surrendered more than 93.1 The oddsmaker predicts 100—what a seemingly odd forecast. But then he adds, “by the way, I think there’s a 77–95% chance the Cardinals will give up fewer points than that.” Now the oddsmaker is just rude; perhaps he doesn’t think so poorly of the Cardinals’ chances, but he certainly didn’t give his best estimate when he predicted 100 points for the other team. In the current dispute, ERISA told an actuary to give his best estimate of the withdrawal liability of Ace-Saginaw Paving Company (Ace). Instead, he gave an estimate that he believed would overcount Ace’s withdrawal liability 77–95% of the time. Because he did not give his best estimate, we affirm the district court and hold that his estimate violated 29 U.S.C. § 1393(a)(1).

A Bristol man was sentenced today to more than 24 years in federal prison for distributing fentanyl that led to a fatal overdose, the U.S. Attorney’s Office for the Eastern District of Tennessee announced in a press release. U.S. District Judge Clifton L. Corker handed down the 292-month sentence, followed by three years of supervised release. Whitaker pleaded guilty to distributing fentanyl-laced counterfeit Roxicodone pills that caused a person’s death in Sullivan County in 2023. He was arrested in April 2024 after fleeing a traffic stop and was found in possession of a large quantity of fentanyl pills, $13,754 in cash, and more than 130 firearms, including stolen weapons. The case was part of Operation Take Back America and involved several local, state and federal agencies.

The U.S. Supreme Court said Friday it will review the constitutionality of a key provision of the 1965 Voting Rights Act in a case involving Louisiana’s congressional map, which was amended to add a second Black-majority district. The justices will consider whether using race to create such districts as a remedy for violations of the act conflicts with the Constitution’s equal protection clause, Reuters reports. The court previously heard arguments in the case in March. But in June, the justices declined to issue a ruling and indicated they would invite the parties to address additional questions. The decision is expected by June 2026. 

U.S. Sen. Marsha Blackburn of Brentwood has announced her candidacy for Tennessee governor. Blackburn is the state's longest-serving Republican woman at the federal level. "I'm running for governor to ensure Tennessee is America's conservative leader for this generation and the next," she said, Knox News reports. The primary election to replace term-limited Gov. Bill Lee is Aug. 6, 2026. Blackburn will face U.S. Rep. John Rose, Republican of Cookeville, who announced his candidacy March 20. Memphis City Council member and attorney Jerri Green announced her candidacy in July for the Democratic primary.

Tensions between community members and the Fayette County School Board have increased as the district continues efforts to push toward dissolving the consent decree that has held the school system accountable to the federal government for integrating public schools since 1965. According to the Tennessee Lookout, an order from U.S. District Court Judge S. Thomas Anderson in 2023 found the school system had worked to eliminate discrimination practices. He revised the consent decree to narrow desegregation obligations to a few remaining areas. Community members who attended school board meetings indicated a lack of trust in the school board’s decision-making processes and consideration of public feedback. Some also criticized the racial makeup of the board as six of the eight members are white, while more than half of the district’s students are Black. Advocates have urged board members to improve communication and public engagement as the district considers its next steps in the federal case.

A woman has filed a $6 million lawsuit against FedEx, alleging she was fired for repeatedly reporting a coworker’s racist comments. The lawsuit was filed in federal court on July 26, with an amended complaint submitted on July 30. According to the Commercial Appeal, Barbara Blake, a Black former security guard, claims she was wrongfully terminated in March 2024 after reporting that a white coworker used racial slurs and made references to police brutality. Blake said she initially reported the comments to her supervisor, who took no action. She says she was twice suspended in retaliation for reporting the behavior and reporting her supervisor’s inaction. The coworker also filed a complaint against Blake. FedEx later fired Blake citing complaints about her conduct and alleged use of threatening language. In a statement to the Commercial Appeal, FedEx said it “is committed to maintaining a workplace that is free from discrimination of any kind.”

The TBA’s Adoption Law Section will host its 2025 Adoption Law Forum on Sept. 19, offering a full day of programming on legislative and case law updates, child development and a judicial panel. The forum will take place from 9 a.m. to 3 p.m. CDT at the Tennessee Bankers Association in Nashville. More details about the event and speakers will be announced soon on the TBA website.

A proposal to build a new jail and relocate all criminal and civil justice institutions in Shelby County to the former Firestone plant site in north Memphis recently was presented to the Shelby County Commission. According to the Daily Memphian, the first phase of the estimated $1.3 billion plan would move the county jail and criminal courts from downtown to the 71-acre site. Future phases could include relocating civil and federal courts. The second phase would build new facilities for chancery, circuit, general sessions and probate courts, while the third phase would add the Shelby County Sheriff’s Office training facility, the Mark Luttrell Transition Center, the Shelby County Corrections Facility and the Federal Correctional Institution of Memphis. Kemp Conrad, who presented the proposal, said leaders have met with community advocates and stakeholders over the last seven months to discuss the new site, which could be completed in three years.