Tennessee lawyers are reminded to submit comments about the Tennessee Supreme Court's Sept. 16, 2025, order on potential regulatory changes to the legal profession. Survey responses are due by Feb. 20. The survey should take less than 10 minutes to complete and all responses are anonymous. To help you prepare, the TBA has compiled background materials on a dedicated resource page. We encourage you to review those materials before submitting your responses. The TBA also is holding a series of virtual town halls to gather feedback from the legal community. Each event will focus on one or two specific areas of potential regulation. See the list of remaining events.

The Tennessee Supreme Court on Sept. 16, 2025, issued an order inviting public comment on legal access and potential regulatory reform. In the order, the court noted it is reassessing how the profession is regulated “to ensure that all Tennesseans have access to affordable quality legal services.” These issues could have a significant impact on the practice of law in our state. The Tennessee Bar Association wants to hear directly from you. We invite you to share your perspective on the seven issues outlined in the court’s order by completing this brief survey. It should take less than 10 minutes to complete and all responses are anonymous. To help you prepare, the TBA has compiled background materials on a dedicated resource page. We encourage you to review those materials before submitting your responses. The survey will remain open until 11:45 p.m. CST on Feb. 20. The TBA also is holding a series of virtual town halls to gather feedback from the legal community. Each event will focus on one or two specific areas of potential regulation. See the list of events.

The TBA YLD has selected six fellows for its Rural Judicial Fellowship (RJF) program. They are: Johnny Byrd, Rachel Carpenter, Laila Irigoyen and Alana Perez from Belmont University College of Law; Sarah Harper from Lincoln Memorial University Duncan School of Law; and Savannah Beaty from University of Tennessee Winston College of Law. These law students will have the opportunity to spend six weeks of the summer as a judicial law clerk in a legal community in rural Tennessee. They also will attend the TBA's Annual Convention in June. Six judges will be paired with the students to help them gain practical legal experience and foster connections in underserved areas. Thank you to this year's participating judges: Circuit Court Judge Caleb Bayless in Columbia, Chancellor Jerri Bryant in Athens, General Sessions Judge Lee Bussart in Lewisburg, Circuit Court Judge Mark Hayes in Dyersburg, Circuit Court Judge Blake Neill in Somerville, and Criminal Court Judge Zachary Walden in Jacksboro. Thanks also to YLD Middle Tennessee Governor Alix Rogers and YLD Secretary Judge Zack Walden who co-chair the Rural Judicial Fellowship program.

The TBA Leadership Law (TBALL) Class of 2026 met in Memphis for its “Issues in Community Leadership” program. The class toured St. Jude Children’s Research Hospital and were welcomed by Sara Hall, chief legal officer and general counsel at ALSAC, the fundraising organization for St. Jude. University of Memphis School of Law Professor Daniel Kiel and members of the Memphis 13 — the African American first-graders who integrated four all-white Memphis elementary schools in 1961 — shared their experiences with the class. The group also heard from Bruce McMullen of Baker Donelson regarding removal of confederate statues in Memphis parks. Additional highlights included a welcome from TBALL co-chairs Geoffrey Lewis and John Wilks, a Myers-Briggs leadership assessment led by Linda Bailey, a “Lunch & Learn” with Tennessee Supreme Court Chief Justice Holly Kirby and Justice Mary Wagner. See photos from the events.

JOHN K. BUSH, Circuit Judge. Thanks in no small part to Americans’ love for dogs, rabies no longer spreads among dogs in the United States. The same is not true elsewhere. Starting in 2015, bad actors exploited a vulnerability in the dog importation regulations of the Centers for Disease Control and Prevention (CDC) and brought rabid dogs into the United States. In response, the CDC modified its existing regulation (the Dog Rule) through notice and comment rulemaking to require that (1) all dog importers submit a Dog Importation Form (DIF), (2) all dogs coming into the United States have a microchip, and (3) all such dogs be at least six months old. The plaintiffs say that the CDC has barked up the wrong tree. They sought a preliminary injunction against enforcement of the Dog Rule’s age and microchip requirements, arguing that these two requirements exceed the CDC’s statutory authority and were promulgated via arbitrary and capricious rulemaking.1 The district court denied the motion, reasoning that the plaintiffs failed to show a likelihood of success on the merits. We agree with the district court and AFFIRM.

KAREN NELSON MOORE, Circuit Judge. Amid their divorce proceedings, Amanda Hovanec killed her husband, T.H., by injecting him with etorphine, a large-animal tranquilizer. Anthony Theodorou, a man with whom Hovanec was romantically involved, shipped the etorphine to Hovanec from South Africa at her request. Hovanec and Theodorou disposed of the evidence after the murder, and Hovanec’s mother, Anita Green, drove them to bury T.H.’s body in the woods. When the hotel at which T.H. was staying informed the police that he had not checked out as expected, authorities began investigating and arrested Hovanec, Theodorou, and Green. Theodorou and Hovanec were indicted for conspiracy to import a controlled substance, importation of a controlled substance, conspiracy to possess a controlled substance with intent to distribute, and distribution of a controlled substance with enhancements for causing death. Green was indicted for being an accessory after the fact. Hovanec, Theodorou, and Green all pleaded guilty. Hovanec appeals her 480-month sentence; Green appeals her 121-month sentence and the district court’s restitution order requiring her to pay for her grandchildren’s psychological care. For the reasons that follow, we AFFIRM Green’s and Hovanec’s sentences and REVERSE and REMAND Green’s restitution order for further proceedings consistent with this opinion.

A Shelby County jury convicted the Defendant of one count of rape of a child. By consent of the parties, the trial court sentenced the Defendant as a standard offender to twenty-five years’ incarceration, to be served at one hundred percent. In this direct appeal, the Defendant contends that the evidence is not sufficient to support his conviction and that the trial court erred in limiting his cross-examination of one of the prosecution witnesses. We affirm the judgment of the trial court.

Petitioner, Alejandro Avila-Salazar, appeals the denial of his pro se “Petition For a Writ of Habeas Corpus[,] Rule 36.1 Motion to Correct an Illegal Sentence[,] Petition for Common Law Writ of Certiorari.” After a thorough review of the record and applicable authorities, we affirm the trial court’s judgment.

Petitioner, Jeffrey Lee Potts, claims the post-conviction court erred by denying his petition for relief from his conviction for attempted second degree murder. On appeal, Petitioner claims (1) that Tennessee Code Annotated section 40-30-110(f), which requires that petitioners prove “allegations of fact by clear and convincing evidence,” is inconsistent with Strickland v. Washington, 466 U.S. 668 (1984), and “erects an unconstitutional barrier to relief” and (2) that trial counsel rendered ineffective assistance by failing to obtain and call a use-of-force expert witness at trial. Discerning no error, we affirm the judgment of the post-conviction court.

A Sullivan County jury convicted the Defendant, Randall Lee Neece, of first degree premeditated murder. On the first day of trial, the Defendant moved for a change of venue, asserting that a newly installed “Victims of Violent Crime” monument outside the courthouse prejudiced prospective jurors. The trial court denied the motion, and the Defendant was convicted as charged. On appeal, the Defendant does not challenge the denial of a venue change or the adequacy of voir dire but instead contends that the sworn jurors were exposed to extraneous prejudicial information through the monument. Upon our review, we conclude that this claim was not preserved for plenary review and does not warrant plain error relief. We therefore respectfully affirm the judgment of the trial court.