The state Department of Revenue on Monday extended the deadlines for franchise and excise tax filing to May 22 for businesses located in counties that were designated federal disaster areas as a result of January’s winter storm Fern. Those include Davidson, Williamson, Wilson, Cheatham and more. Those affected will have additional time to file returns and make payments that were due beginning with Jan. 22. Due dates after May 22 will not be altered or extended. Read more in a press release or official notice from the department.

THAPAR, Circuit Judge. Juan Luis Gamas-Vicente illegally entered the United States in 2014. He conceded that he was removable but has spent the last decade seeking asylum, withholding of removal, and protection under the Convention Against Torture. An immigration judge rejected his application, and the Board of Immigration Appeals affirmed. They concluded that Gamas-Vicente didn’t establish that he is a member of a particular social group facing persecution. We agree, so we deny his petition for review.

DAVIS, Circuit Judge. Pharmacy benefit managers—referred to in the industry as PBMs—play a pivotal role in American healthcare. They oversee prescription-drug benefits for health plans, perform administrative services, help negotiate drug rebates, and set up pharmacy networks, working with health plans, drug manufacturers, and pharmacies along the way. But the rise of PBMs has been met with state-level regulation efforts. PBMs often own pharmacies to which they steer significant business, and in the process build a significant market share of the prescription-drug benefit field in a given geographic area. Some policymakers have raised concerns that such practices can lead to the closure of small, rural pharmacies. Citing this policy concern, Tennessee enacted laws to tamp down the PBM practice of steering patients to PBM-managed pharmacies. These laws ban interference with a patient’s choice of pharmacy and restrict the provision of incentives for patients to choose certain pharmacies over others. These restrictions sweep in self-funded health plans that are governed by the Employee Retirement Income Security Act (“ERISA”), 29 U.S.C. § 1001 et seq., running headlong into that Act’s preemption provision and the Supreme Court’s decision in Rutledge v. PCMA, 592 U.S. 80 (2020). All this led to the present suit and the question we confront today: Does ERISA preempt Tennessee’s PBM-focused laws? The district court thought so, and we agree. Hence, for the reasons that follow, we AFFIRM.

Defendant, Jerome Nchiyako Dooley, pled guilty to one count of sexual battery and received an agreed sentence of five years as a Range III offender, to be served on probation. Following a hearing on a warrant for violation of his probation, the trial court revoked Defendant’s probation and ordered him to serve his original sentence incarcerated. Defendant appeals, arguing that the trial court erred in revoking probation based on a video Defendant posted to TikTok and that the court erred in failing to recuse itself sua sponte. Following a review of the entire record, the briefs and arguments of the parties, and the applicable law, we affirm the judgment of the trial court.

This appeal presents issues relating to the probate court’s admission of a copy of a will for muniment of title. However, we do not reach the merits of the appeal due to Appellant’s failure to comply with the briefing requirements outlined in Tennessee Rule of Appellate Procedure 27(a), and Rule 6 of the Rules of the Court of Appeals of Tennessee.

The plaintiff filed an action in the Davidson County general sessions court to recover the balance of an unpaid loan from the defendant. An agreed final order was entered in favor of the plaintiff. Approximately six months later, the defendant filed a motion to set aside the judgment based on an alleged fraudulent misrepresentation perpetrated by the plaintiff. The general sessions court denied the motion. The defendant appealed the denial to the Davidson County circuit court. The plaintiff filed a motion to dismiss the appeal. The circuit court held that because the defendant had failed to file the motion to set aside within the ten-day statutory period outlined in Tennessee Code Annotated section 16-15-727(b), the general sessions court had correctly dismissed the motion as it lacked jurisdiction to set aside the judgment. Likewise, the circuit court held that it lacked jurisdiction to hear an appeal on the merits as an appeal had not been timely filed. The defendant appeals. We affirm.

This appeal arises from a petition to terminate the parental rights of a father for the purposes of adoption. The petitioners, the child’s stepfather and mother, alleged that the father abandoned the child both by failing to visit and by failing to support. When father failed to participate in discovery, the petitioners moved for a default as a sanction. After granting the requested default and holding an evidentiary hearing, the trial court concluded that there was clear and convincing evidence of abandonment and that termination of father’s parental rights was in the child’s best interest. Finding no reversible error, we affirm the termination of parental rights.

Tennessee Attorney General (AG) Jonathan Skrmetti on Monday sent a letter to Acting U.S. AG Todd Blanche, asking the Department of Justice (DOJ) to reconsider its proposed rule that any ethics complaints made against DOJ attorneys would be reviewed by the department before a state, territory or District of Columbia disciplinary investigation could occur. The letter reads, in part, "While the Proposed Rule responds to a real problem, it unconstitutionally infringes on the prerogatives of the state judiciary contrary to the Tenth Amendment and black-letter federal law," and that the proposal "risks eroding key structural components of our constitutional order by intruding on the States' authority to regulate the legal profession and Congress's choice to reinforce that traditional role for the States with respect to attorneys for the federal government." Read the letter here. In related news, the American Bar Association and a group of 20 attorneys general also filed comments opposing the rule. Reuters reports on the state group.

The Tennessee Registry of Election Finance on March 31 dismissed a complaint against Republican U.S. Sen. Marsha Blackburn, ruling that her use of federal campaign funds falls under Federal Election Commission (FEC) jurisdiction rather than state authority. The complaint, filed by Knoxville Republican Gary Loe, alleged Blackburn improperly used her U.S. Senate campaign account to fund her gubernatorial run. According to Knox News, state officials found she did not violate state law because her governor's campaign account was not yet open when the disputed spending occurred, and because Tennessee's ban on using federal funds for state purposes only applies to direct transfers between accounts. Blackburn, who announced her gubernatorial bid in August, is running in the Aug. 5 Republican primary against state Rep. Monty Fritts and U.S. Rep. John Rose.

Join the TBA Mentoring Committee and the TBA Young Lawyers Division for the May monthly mentoring meet up at a Nashville Sounds game! We have a block of tickets in the 4 Tops section on May 28, perfect for making connections in a relaxed setting. Tickets are only $20. Half the price, all the fun — thanks to the TBA covering the other half. All are welcome and guests are encouraged. Come connect, build relationships and enjoy the game with the mentoring community! See a flyer for more information and purchase tickets here. Tickets are limited. Learn more about the TBA Mentoring Committee on the TBA website.