The Tennessee Department of Revenue will host a free webinar on July 9 designed for new businesses. Participants will learn about state tax obligations and resources that are available for new businesses in Tennessee. Register for the webinar or view all upcoming educational events from the department.

Defendant, Corridirus Qualls, was convicted of one count of first degree premeditated murder; two counts of attempted second degree murder; one count of reckless endangerment by discharging a firearm into an occupied habitation; two counts of employing a firearm during the commission of a dangerous felony; two counts of aggravated assault; and one count of reckless endangerment. The trial court sentenced Defendant to a total effective sentence of life plus eighteen years. On appeal, Defendant argues that (1) the evidence was insufficient to support his convictions and (2) the trial court abused its discretion by imposing partial consecutive sentencing. After review, we affirm the judgments of the trial court.

NALBANDIAN, Circuit Judge. Deangelus Thomas was indicted on two counts of being a felon in possession under 18 U.S.C. § 922(g)(1) for his role in a shooting. Though his indictment gave him notice that he might be subject to enhanced penalties based on his criminal history, he was not formally indicted as an armed career criminal. At trial, a jury found him guilty of both felon-in-possession counts. Throughout sentencing, Thomas maintained that he could not be sentenced under the Armed Career Criminal Act (ACCA). 18 U.S.C. § 924(e)(1). Because he had never been indicted for it, and the jury had not found the essential fact —that he had three prior violent- felony convictions committed on different “occasions, ” —he claimed he could only be subject to the penalties associated with § 922(g)(1). Otherwise, his Fifth and Sixth Amendment rights would be violated. The district judge disagreed. Following then-binding Sixth Circuit precedent, the judge found the fact of Thomas’s three prior convictions by a preponderance of evidence at sentencing, and imposed an enhanced, 432-month sentence on Thomas. We affirmed. But the Supreme Court later decided Erlinger v. United States, 602 U.S. 821 (2024), which held that the Fifth and Sixth Amendments require a jury to find the three-occasions element of an ACCA conviction. Now, Thomas is back before us. He argues that Erlinger is a form of structural error and requires automatic reversal. As a remedy, he argues for a remand to the district judge for resentencing based on the crime he was convicted of by a jury—the unenhanced § 922(g)(1). Because our circuit has already decided that Erlinger errors are subject to harmless error, we affirm his sentence because the failure to charge the jury was harmless.

In this post-divorce proceeding, Appellant initiated a contempt action against Appellee for failure to make two alimony payments, as required under the parties’ marital dissolution agreement (“MDA”). After Appellee remitted payment, the sole issue to be tried was the amount of attorney’s fees Appellant expended enforcing the MDA. Appellant sought $14,289.50 in attorney’s fees and $396.36 in expenses. The trial court awarded her $2,500.00. Because the trial court made limited findings and failed to consider Rule 1.5(a) of the Tennessee Rules of Professional Conduct, we vacate its award of attorney’s fees. On remand, the trial court is instructed to reconsider Appellant’s attorney’s fee award in view of the Rule 1.5(a) factors and to make written findings consistent with these factors. Husband’s request for appellate attorney’s fees is denied.

Following an automobile accident allegedly involving a State of Tennessee employee, claimant sought damages against the State based on alleged injuries arising from the accident. The Division of Claims and Risk Management denied the claim, and claimant appealed to the Claims Commission. Because claimant’s appeal was not filed within the ninety-day statutory time limit, the Claims Commission dismissed it. Finding no error, we affirm.

Tennessee Attorney General (AG) Jonathan Skrmetti recently announced the opening of the new Civil Rights Enforcement Division (CRED), which is now accepting discrimination complaints under the Tennessee Human Rights Act and Tennessee Disability Act. This past legislative session, the Tennessee General Assembly approved SB861/HB910 to dissolve the Tennessee Human Rights Commission and create the Civil Rights Enforcement Division within the AG's office to provide civil rights enforcement. The division will serve as a specialized unit combating illegal discrimination in employment, housing, public accommodations and education in Tennessee. Tennesseans who believe they have experienced unlawful discrimination can file complaints with CRED here. Read more in a press release from the office. Any complaints pending with the commission must be filed again with CRED within 90 days according to The Tennessean.

An employee discharged in a reduction-in-force claimed her employer discriminated against her. The trial court determined that the employee was unable to establish a prima facie case of discrimination and granted summary judgment to the employer. We affirm.

A draft report from the Tennessee Advisory Commission on Intergovernmental Relations is recommending that the state build a Tennessee Bureau of Investigation (TBI) crime lab in Chattanooga to reduce the time needed to examine evidence in criminal cases. According to Chattanoogan.com, for years, law enforcement officers from the Chattanooga area have had to transport evidence primarily to Nashville. The proposed Chattanooga lab would be smaller than the state's other labs in Knoxville, Jackson and Nashville and would focus on drug-related evidence and toxicology. The draft report also finds that all three existing labs are running out of space and need to be expanded. The report calls for expanding lab space, hiring additional analysts and using process improvement methods to keep pace with rising caseloads. Despite recent hirings and investments that have improved some turnaround times at the labs, demand for testing continues to grow, the news source reports.

The Davidson County Jail recently failed a state inspection for the first time in several years due to overcrowding. Sheriff Daron Hall told News Channel 5 that the downtown Nashville facility is experiencing overcrowding and has no way to increase capacity. The current jail was built just five years ago and cost $200 million. Hall also says that the jail's Harding Place campus, south of downtown, must be replaced to increase capacity and for safety. He says the city is "spending over a million dollars a year on band aids on those facilities." Total capacity at the two campuses is about 2,300 inmates. Combined they are currently housing 300 inmates over capacity.

A federal judge on Wednesday blocked President Donald Trump’s asylum ban for the southern border, determining it runs afoul of immigration laws protecting the rights of those seeking refuge in the U.S. The decision from U.S. District Court Judge Randolph Moss blocks an executive order that ended asylum for all but those who enter the U.S. at designated ports of entry. Moss found the order violated the Immigration and Nationality Act (INA), which lays out guidelines for who qualifies for asylum and how they can seek the protections. Moss also rejected the idea that Trump has inherent presidential authority over decisions of who enters the country. He postponed implementation of the ruling for 14 days to give the administration an opportunity to appeal. The suit was brought by the American Civil Liberties Union on behalf of 13 anonymous asylum seekers, the Refugee and Immigrant Center for Education and Legal Services, Las Americas Immigrant Advocacy Center and the Florence Project. The Hill has more on the decision.