CHAD A. READLER, Circuit Judge. Bhavanaben Patel petitions on behalf of herself, her husband, and her two sons to review the Board of Immigration Appeal’s decision rejecting their applications for asylum, withholding of removal, and protection under the Convention Against Torture. Seeing no error in the Board’s decision, we deny the petition. For these reasons, we deny the petition for review.

This appeal arises from a lawsuit over defamation and false light invasion of privacy. Ronald Austin and Linda Austin (“Mr.” and “Ms. Austin,” respectively) (“Plaintiffs,” collectively) were neighbors of Angela Kay Plese (“Defendant”). Plaintiffs and Defendant did not get along. At one point, Defendant posted certain statements on Facebook about Ms. Austin, including that Ms. Austin had been convicted in Texas of deadly conduct with a gun. While Ms. Austin had pled guilty many years earlier to a Texas statute called “deadly conduct,” this was in the context of her reaching a better deal in a DUI case. Ms. Austin’s matter did not involve a gun. Plaintiffs sued Defendant for defamation and false light in the Circuit Court for Knox County (“the Trial Court”). After a trial, the Trial Court found in favor of Plaintiffs, awarding $95,100 in total damages for Ms. Austin’s medical expenses, damage to reputation, emotional distress, punitive damages, as well as Mr. Austin’s loss of consortium.1 Defendant appeals. We vacate that portion of the Trial Court’s award concerning damage to Ms. Austin’s reputation since the record contains no evidence of such damage. Therefore, we modify the judgment to $75,100. Otherwise, we affirm.

The TBA Leadership Law (TBALL) was in Knoxville last week for an "Issues in Community Leadership" session. The class heard from several Tennessee leaders including Knoxville Mayor Indya Kincannon, Knox County Mayor Glen Jacobs, Supreme Court Justice Dwight E. Tarwater and former Attorney General Herbert Slatery. Other contributors at the event included Chloe Akers, Professor Akram Faizer, Josh Hedrick, Angelia Nystrom, Robbie Pryor, Professor Joy Radice and Cullen Wojcik. TBALL’s next session will take place April 10-11 in Memphis. Learn more about TBALL or see photos from the event.

In this month's episode of BarBuzz, TBA Executive Director Sheree Wright speaks with Liz Todaro, TBA director of access to justice and special projects, and John Farringer, a commercial litigator with Sherrard Roe Voigt & Harbison and TBA’s incoming president for the 2027-2028 bar year. The discussion focuses on the Administrative Office of the Courts’ plan for funding indigent representation, a key issue shaping legal access in Tennessee. The group also talks about the importance of TBA's Day on the Hill and Big Shrimp Legislative Reception, two events that connect legal professionals with lawmakers to advocate for issues such as indigent defense funding. TBA’s 2025 Day on the Hill and Big Shrimp Reception will take place next week in Nashville. Register for the day's events on the TBA website or get more information about indigent defense in Tennessee. Find past episodes of the podcast in the BarBuzz archive.

An Alabama couple has filed suit against the Tennessee Department of Children’s Services (DCS) and Sevierville law enforcement alleging their two children were illegally taken for nine months after they were wrongly arrested during a traffic stop, Tennessee Lookout reports. The couple was charged with DUI, public intoxication, child abuse and neglect, and aggravated child abuse and neglect. The parents denied the charges, which were later dismissed by a local prosecutor and subsequently expunged. They also claim that law enforcement did not have probable cause to pull them over. The couple are seeking $15 million in damages for violation of their constitutional rights and $10 million in damages for state law violations. This lawsuit is similar to one filed last year after a Georgia family was stopped in Coffee County and five children were taken from the parents.

The Voyeurism Victims Act unanimously passed the House 93-0 on Monday and now will go to Gov. Bill Lee's desk for his signature. Matthew Vollmer was arrested in November and charged with illegally recording sexual encounters with four women without their consent. The women banded together to push for legislation to change the statute of limitations for bringing a lawsuit to one year past the date of discovery, rather than the date of the original crime, giving victims more time to pursue justice. The bill also will allow victims of unlawful photography to petition for an order of protection. The Tennessean reports that the legislation will not apply retroactively, but the women in the case say they want to change the law to help future victims of similar crimes. The Senate passed the bill March 3 in a 32-0 vote.

The Tennessee House of Representatives on Monday passed a bill that would eliminate race-based policies like affirmative action, racial preferences and racial quotas from being used when making appointments to state boards, including specifically removing rules requiring the governor to strive to ensure at least one person on certain state boards is a member of a racial minority, reports the Nashville Post. Lead sponsor Rep. Jason Zachary, R-Knoxville, says the purpose of HB1237/SB1235 is to align the state with a 2023 Supreme Court ruling that found such race-based programs violate the equal protection clause of the 14th Amendment. Opponents of the bill expressed concern over the potential for disparities in certain appointed boards or committees, and pointed out that affirmative action policies are not meant to give members of minority groups an unfair advantage. Senate sponsor, Sen. Paul Rose, R-Covington, asked the Senate Judiciary Committee to move the bill to next week’s calendar.

The Tennessee Bar Association is now accepting nominations for its 2025 Claudia Jack Award and Justice Frank F. Drowota III Outstanding Judicial Service Award. The Claudia Jack Award honors an outstanding public defender or court-appointed private practitioner who has served the legal community and clients in an exemplary fashion. It is named after the late Claudia Jack, a public defender and long-time champion of the poor and underprivileged. The Drowota Award is given to a judge or judicial branch official of a federal, state or local court in Tennessee who has demonstrated extraordinary devotion and dedication to the improvement of the law, the legal system and the administration of justice, as exemplified by the career of former Tennessee Supreme Court Justice Frank F. Drowota III. The deadline to submit nominees for both awards, which will be presented at the TBA Annual Convention in June, is April 4.

Knoxville attorney Edward Bruce Foster Jr. died March 7 at age 88. Foster earned his undergraduate degree in business from the University of Tennessee (UT) and his law degree from the UT College of Law. Following law school, Foster received a commission as a first lieutenant in the U.S. Army Judge Advocate General’s Corps, serving on active duty in France from 1959-1963. In 1991, he joined Bass, Berry and Sims, opening its first Knoxville office. Foster served as president of the Knoxville Bar Association, was a member of the Tennessee State Constitutional Convention of 1977, and served as a special justice on the Tennessee Supreme Court during Gov. Lamar Alexander’s administration. A memorial service will be held at 4 p.m. EDT on April 12 at Second Presbyterian Church, 2829 Kingston Pike, Knoxville 37919, with a reception to follow. In lieu of flowers, the family requests that memorial donations be made to Second Presbyterian Church, the E. Bruce and Mary Evelyn Foster Scholarship at UT Law, Knoxville Knox County-CAC Mobile Meals, or do what Foster did best — do something kind for someone else.

General, Solo, & Small Firm Section members have access to quality TBA CLE programming that can be purchased using a section member discount. Join us for upcoming ethics courses featuring Stuart Teicher: Wedded Bliss and Attorney Ethics, Ted Lasso and Attorney Ethics: Lessons in Life, Law, and Leadership, and The Perfect Pop Song and Attorney Ethics. Brush up on your elder law knowledge at the Elder Law Basics program coming up in April. Also next month, join colleagues for a Rookie Series webcast covering Criminal and Civil Contempt, a program dedicated to supporting service members, veterans, and their families or focus on your mental health at our Yoga, Mindfulness & Meditation for Legal Professionals program. Looking for something else? Check out the TBA CLE catalog to find more courses focused on the needs of solo and small firm practitioners!