Knox County has dismantled the long-standing leadership at the Richard L. Bean Juvenile Detention Center following reports of alleged poor medical care, missing medication and retaliatory firing of whistleblowers. An 18-month transition plan approved by county commissioners will place control of the facility under the Knox County Sheriff's Office (KCSO) effective Jan. 1, 2026, while oversight will be provided by a newly appointed board and continued check-ins by the Tennessee Department of Children’s Services. The shift drew criticism due to concerns about the sheriff’s department, including a recent inmate death at the county jail. The overhaul follows the forced resignation of Richard Bean, who had run the facility since 1972 allegedy with little oversight and a handpicked board of trustees. Knox News has the story.

In this webcast replay, Stuart Teicher tells true stories about lawyers who break the law and the ethics rules they break (or could have broken). This session is about a judge who harassed his staff, played favorites with lawyers and conducted himself in a professionally questionable manner. Ethics topics include the connection between competence, withdrawal and mental health issues; how sexual harassment creates problems; the duty to report lawyer and judicial misconduct; and how the rule on supervision guides lawyers in creating an ethically positive office environment. Visit the TBA website to register.

JULIA SMITH GIBBONS, Circuit Judge. Having voluntarily waived his right to a jury trial under Federal Rule of Criminal Procedure 23(a), Defendant Jtton Edward Watson1 was found guilty of felony possession of a firearm in violation of 18 U.S.C. § 922(g)(1) at the conclusion of a bench trial. On appeal, Watson challenges the district court’s denial of his motion to suppress evidence obtained from a vehicle search conducted on December 5, 2020, arguing that the initial traffic stop, his warrantless arrest, and the subsequent search of his vehicle violated his Fourth Amendment rights. He also challenges his conviction under 18 U.S.C. § 922(g)(1), arguing that the conviction was not supported by sufficient evidence. We conclude that the district court did not err in denying Watson’s motion to suppress because (i) the initial traffic stop was supported by probable cause, (ii) Watson’s arrest was supported by probable cause, and (iii) the search of Watson’s vehicle was permissible under the automobile exception. Additionally, Watson’s conviction was supported by sufficient evidence. Accordingly, we affirm.

BUSH, Circuit Judge. Aaron Pulsifer was fired from his job as the Dean of Students and Assistant Principal at Westshore Christian Academy. He then sued the Academy under a variety of state and federal laws that prohibit discriminatory employment practices. The district court granted summary judgment to the Academy, holding that the federal Constitution precludes review of the Academy’s employment decisions vis-à-vis Pulsifer because he performed important religious functions at the school. We agree with the district court and AFFIRM.

GRIFFIN, Circuit Judge. Defendant David Parkey pleaded guilty to causing a minor to engage in sexually explicit conduct for the purpose of producing child pornography. Over Parkey’s objections, the district court applied two Sentencing Guidelines enhancements for using a minor to commit the offense and for engaging in a pattern of prohibited, sexually explicit activity. For the following reasons, we affirm.

CHAD A. READLER, Circuit Judge. A rambunctious groundhog’s turn-of-the-twentieth century antics led to the creation of a Northwest Ohio community treasure and, more recently, a federal tax dispute. To understand why, turn back the clock to the spring of 1900, when an overgrown groundhog ran loose in the furniture store of Toledo businessman Carl Hillebrand. A quandary arose. On one hand, the marmot posed a grave risk to Hillebrand’s inventory. True to their “woodchuck” alias, groundhogs are known to gnaw on wood, including furniture. And this one evidently had a penchant for chewing. Yet on the other hand, Hillebrand, to his credit, did not want to exterminate his furry visitor. But a solution would soon surface. As luck would have it, local park officials had a growing interest in opening a zoo. So Hillebrand offered his pesky patron to a park superintendent, who gladly accepted, and in turn put the animal on display for visitors. Perhaps like those sizing up tax law at first blush, observers faced some initial confusion. Onlookers thought they were witnessing a baby bear, not a groundhog, on account of the animal’s large size. Word of the enclosed supposed omnivore quickly spread, with crowds flocking to witness the seeming hog-in-bear’s clothing. The exhibition did gangbusters. And with that, the Toledo Zoo was launched. See Toledo Stories: The Toledo Zoo: A Living History, at 4:23 (PBS television broadcast, aired Oct. 24, 2002). By any metric, the Zoo has achieved much success over the ensuing century-and-a- quarter. It has grown to house over 16,000 animals. Visit Our Animals, Toledo Zoo & Aquarium, https://perma.cc/K6DY-5Z7G (last visited July 9, 2025). It welcomes over one million visitors each year. See Toledo Zoo & Aquarium, 2023 Annual Report 6 (Aug. 14, 2024), https://perma.cc/96F4-82XB. And it has garnered accolades. See, e.g., Press Release, Jen Brassil, Dir. of Pub. Rels. & Commc’ns Events, Toledo Zoo & Aquarium, The Toledo Zoo Honored with the 2023-2024 CILC Pinnacle Award (Aug. 26, 2024, at 4:00 ET), https://perma.cc/HH3P-H3HU (announcing that the Toledo Zoo received the Center for Interactive Learning and Collaboration’s Pinnacle Award in recognition of its educational programming efforts). The Zoo’s success has no doubt been fueled by generations of generous donors, all dating back to Hillebrand. Count Peter McGowan, a Toledo-area dentist, among those altruistic ranks. For several years, McGown regularly donated to the Toledo Zoo. Although his contributions waned as his children aged, McGowan purportedly envisioned making another substantial gift later in life: No. 24-3228 McGowan v. United States Page 3 the cash value of his life insurance policy. The tax ramifications of McGowan’s complicated plan to potentially bestow that gift eventually resulted in federal court litigation, and now this appeal. McGowan’s case centers on the following arrangement: Over five years, McGowan’s solely owned dental practice, Peter E. McGowan DDS, Inc. (the Company), contributed $50,000 annually to two “subtrusts,” one of which owned a life insurance policy covering McGowan. If the policy paid out upon McGowan’s death, it would benefit his wife. But if the policy-owning subtrust failed to pay a premium during the policy’s life, the subtrust would surrender the policy and transfer all cash value proceeds to the other subtrust. The latter subtrust, in turn, would contribute the money to a charity of McGowan’s choice. Like Hillebrand, McGowan chose the Toledo Zoo. This collection of subtrusts and potential philanthropy was thought to deliver a series of financial benefits to the proclaimed donors. In tax returns McGowan and the Company (collectively, the taxpayers) filed, the Company deducted the policy premiums it paid, with McGowan reporting just a quarter of them as taxable income. But the IRS demurred, asserting that the agency’s “split-dollar” regulation required McGowan to include the full value of the policy’s economic benefits in his gross income and, separately, foreclosed the Company’s attempted deductions. See Treas. Reg. § 1.61-22. It accordingly assessed over $100,000 in unpaid taxes, penalties, and interest between the two parties for tax years 2014 and 2015. Litigation ensued, culminating in the district court’s award of summary judgment to the government. Because the taxpayers land firmly within the split-dollar regulation, McGowan must include the value of the policy’s economic benefits in his gross income each year, and the Company cannot deduct its annual premium payments. And because that regulation comports with our independent reading of the Internal Revenue Code, see I.R.C. §§ 61, 162(a), 419(a), we affirm.

GRIFFIN, Circuit Judge. Plaintiff Karim Codrington was the victim of an unlawful traffic stop, search, and arrest. During the criminal proceedings arising from that stop, a Kentucky state court suppressed the evidence illegally seized from his vehicle and dismissed his criminal charges. More than three years later, Codrington filed this 42 U.S.C. § 1983 lawsuit, claiming that the defendant police officers planted drugs on him, provided those drugs to prosecutors as a basis for his criminal prosecution, and stole thousands of dollars from him. The district court granted summary judgment in favor of defendants on all claims, finding that Codrington’s claims either were barred by the statute of limitations or failed on their merits. Because the district court erroneously found a lack of genuine dispute of material fact regarding Codrington’s fabrication- of-evidence claim, we reverse on that claim. Consequently, we vacate the district court’s derivative judgment in favor of defendants on Codrington’s claims under Monell v. Department of Social Services, 436 U.S. 658 (1978), and remand for further proceedings. As for all other claims, we affirm.

Travis Rogers, Defendant, was convicted by a jury of first degree murder. Defendant challenges the trial court’s denial of the motion for judgment of acquittal made at the close of the State’s proof. After the State rested, Defendant put on proof. Because Defendant waived his challenge to the trial court’s denial of the motion for judgment of acquittal at the close of the State’s proof by putting on proof, we affirm the judgment of the trial court.

The Defendant, Jason Patrick Odom, was convicted by a Davidson County Criminal Court jury of theft of property valued at $2,500 or more but less than $10,000, a Class D felony; burglary of a motor vehicle, a Class E felony; and vandalism of property valued at $1,000 or less, a Class A misdemeanor. See T.C.A. §§ 39-14-103 (2018) (theft of property); 39- 14-105 (2018) (grading of theft); 39-13-1002 (Supp. 2022) (subsequently amended) (burglary); 39-14-408 (Supp. 2022) (subsequently amended) (vandalism). The trial court imposed concurrent sentences of twelve years for theft, six years for burglary, and eleven months, twenty-nine days for vandalism. On appeal, the Defendant contends that (1) the evidence is insufficient to support his convictions and (2) the trial court erred by admitting a photograph into evidence. We affirm the judgments of the trial court.

A Lincoln County jury convicted the Defendant, Juan Manuel Mejia Nunez, of three counts of aggravated sexual battery and two counts of sexual battery by an authority figure. Following a sentencing hearing, the trial court imposed an effective sentence of eighteen years’ incarceration. On appeal, the Defendant contends that the trial court erred by (1) permitting several of the State’s witnesses to remain in the courtroom throughout the trial; (2) admitting testimony that referenced and described the victims’ forensic interviews; (3) admitting testimony from a police investigator about the behavioral characteristics of child sexual abuse victims; and (4) limiting testimony from the victims’ mother regarding the circumstances of her divorce. Upon our review, we respectfully affirm the judgments of the trial court.