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Posted by: Stacey Shrader Joslin on Apr 3, 2025

U.S. District Judge Araceli Martínez-Olguín of San Francisco ordered the Trump administration to temporarily restore legal aid to tens of thousands of migrant children who are in the United States without a parent or guardian. According to NPR, the order will run through April 16. The administration on March 21 terminated a contract with the Acacia Center for Justice, which provides legal services for unaccompanied migrant children under 18 through a network of legal aid groups that subcontract with the center. Eleven subcontractor groups sued, arguing that the government has an obligation under the Trafficking Victims Protection Reauthorization Act of 2008 to provide vulnerable children with legal counsel. The groups said some of the clients are too young to speak and others are too traumatized and do not know English.

Posted by: Stacey Shrader Joslin on Apr 3, 2025

A bill headed for both the House and Senate floors could clarify cases in which an abortion could be legal in Tennessee to preserve the life of the mother, the Nashville Post reports. According to bill sponsor Rep. Bryan Terry, R-Murfreesboro, SB1004/HB990 would not add specific exceptions, but would specify some cases in which an abortion could fall under the state ban’s sole exception of “serious risk of substantial and irreversible impairment of major bodily function.” Conditions in the bill include previable/premature rupturing of membranes, inevitable abortion, severe preeclampsia, mirror syndrome associated with fetal hydrops, and infection that could result in uterine rupture or loss of fertility. During a Senate Judiciary Committee meeting last week, co-sponsor Sen. Richard Briggs, R-Knoxville, said, “… this bill is simply about clarifying and elaborating on the existing ‘life and health of the mother’ exception in current law. Under this bill ‘reasonable medical judgment’ still applies.” In October, a three-judge panel ruled in Davidson County Chancery Court that doctors could perform an abortion from a list very similar to the one in the legislation. An alternative measure, which would have created an exception for “fetal fatal anomalies” was rejected by the Senate committee.

Posted by: Stacey Shrader Joslin on Apr 3, 2025

A bill proposing a one percentage point increase to Shelby County’s sales and use tax passed the Senate State and Local Government Committee on April 2, the Daily Memphian reports. The revenue generated from the tax increase would exclusively fund the construction of a new jail in Shelby County. If the bill were to pass this year, the law would not take effect until passed by the Shelby County Board of Commissioners and then by voters through a county-wide referendum. The legislation is designed to address deteriorating conditions within the jail, which have led to a string of deaths and subsequent lawsuits. Since 2019, the Downtown jail, also known as 201 Poplar, has seen 61 inmate deaths and five so far in 2025. The bill, SB337/HB308 is sponsored by Rep. John Gillespie, R-Memphis, in the House and Sen. Raumesh Akbari, D-Memphis, in the Senate.

Posted by: Stacey Shrader Joslin on Apr 3, 2025

A bill to reinstate voting rights for people convicted of certain felonies passed the Senate State and Local Government Committee on April 1, the Daily Memphian reports. SB336, sponsored by Sen. Raumesh Akbari, D-Memphis, would remove the requirements for persons convicted of certain felonies to have fully paid all court costs associated with their crime to be eligible to vote. It also would remove the requirement to be up to date on child support payments to be eligible to apply for a voter-registration card. Akbari said the bill would help alleviate concerns of financial hardship preventing voting-rights restoration for those who have completed all requirements of their sentence. The bill would not apply to “infamous” felony crimes, which are defined by the state. Individuals convicted of “infamous” crimes are forever ineligible for voting-rights reinstatement under current state law. The House version of the bill, sponsored by state Rep. Karen Camper, D-Memphis, was set for an April 1 vote but was postponed.

Posted by: Azya Thornton on Apr 3, 2025

CLAY, Circuit Judge. This civil rights action arises from the suicide of Tyler Venema. Venema asphyxiated himself with a plastic bag while in the custody of the Michigan Department of Corrections (“MDOC”) and in an inpatient mental health treatment program at Woodland Center Correctional Facility (“WCC”). Defendant Jodi DeAngelo was the warden of WCC at the time of Venema’s death. Venema’s Estate sued DeAngelo in her individual capacity pursuant to 42 U.S.C. § 1983, alleging that DeAngelo was liable for Venema’s death in violation of the Eighth Amendment. Asserting the defense of qualified immunity, DeAngelo moved to dismiss the claim against her. The district court denied the motion, concluding that DeAngelo was not entitled to qualified immunity. DeAngelo timely appealed. For the reasons set forth below, we affirm.

Posted by: Azya Thornton on Apr 3, 2025

NALBANDIAN, Circuit Judge. The Video Privacy Protection Act—as the name suggests—arose out of a desire to protect personal privacy in the records of the rental, purchase, or delivery of “audio visual materials.” Spurred by the publication of Judge Robert Bork’s video rental history on the eve of his confirmation hearings, Congress imposed stiff penalties on any “video tape service provider” who discloses personal information that identifies one of their “consumers” as having requested specific “audio visual materials.” This case is about what “goods or services” a person must rent, purchase, or subscribe to in order to qualify as a “consumer” under the Act. Is “goods or services” limited to audio-visual content—or does it extend to any and all products or services that a store could provide? Michael Salazar claims that his subscription to a 247Sports e-newsletter qualifies him as a “consumer.” But since he did not subscribe to “audio visual materials,” the district court held that he was not a “consumer” and dismissed the complaint. We agree and so AFFIRM.

Posted by: Azya Thornton on Apr 3, 2025

HELENE N. WHITE, Circuit Judge. Defendants-Appellants Jeffrey Campbell and Mark Dyer appeal their convictions and sentences for conspiracy to unlawfully distribute controlled substances, conspiracy to commit health-care fraud, health-care fraud, and money laundering, challenging the jury instructions, sufficiency of the evidence, and the district court’s evidentiary rulings. Finding no error, we AFFIRM.

Posted by: Azya Thornton on Apr 3, 2025

Petitioner, Tarence Nelson, was convicted by a jury of two counts of first degree premeditated murder and sentenced by the trial court to two consecutive terms of life imprisonment. In 2023, Petitioner filed his third petition for writ of error coram nobis (“the third petition”) claiming that a Sig Sauer P229 handgun (“the Sig Sauer”) that he hid in a computer at his home following the 2009 murders was newly discovered evidence. The Sig Sauer was found after Petitioner revealed its location and the coram nobis court by order entered on July 20, 2021, appointed counsel to represent Petitioner on the fingerprint analysis petition filed in conjunction with Petitioner’s second petition for writ of error coram nobis. Because Petitioner knew the location of the Sig Sauer at the time of his trial and because Petitioner was solely at fault in failing to present the Sig Sauer as evidence “at the proper time,” error coram nobis relief is not available. Tenn. Code Ann. § 40-26- 105(b). We affirm the judgment of the coram nobis court in summarily dismissing the petition.

Posted by: Azya Thornton on Apr 3, 2025

The Defendant, Johnny Graham, was convicted of possession of cocaine with the intent to sell or deliver and possession of a firearm by a convicted felon. The trial court sentenced the Defendant to a term of nine years and placed him on probation. Thereafter, the Defendant was arrested for the unlawful possession of cocaine and multiple firearms. Following a hearing, the trial court fully revoked the Defendant’s suspended sentences and ordered him to serve the full term in the Tennessee Department of Correction. On appeal, the Defendant argues that the trial court abused its discretion in fully revoking his suspended sentences. Upon our review, we respectfully disagree and affirm the trial court’s judgments.

Posted by: Azya Thornton on Apr 3, 2025

The Defendant, Jamar Laquinn Frazier, appeals from his conviction for second degree murder following a jury trial. In this appeal, the Defendant claims that the trial court (1) denied him counsel of his choosing by denying his request to continue the trial date; (2) erred by allowing certain testimony at trial in violation of the law of the case doctrine and by allowing improper opinion, character, and hearsay testimony; and (3) erred by imposing the maximum twenty-five-year sentence. Additionally, the Defendant argues that he is entitled to a new trial (4) due to the denial of funding for an investigator during the motion for new trial proceedings and (5) due to cumulative error. After review, we affirm the judgment of the trial court.


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