The TBA Young Lawyers Division met last week at the TBA's 2025 Annual Convention in Franklin. On Friday, the traditional gavel pass was held as Hamilton County Circuit Court Judge Alex McVeagh took office as president. Others taking office were President-elect Jennifer Sneed of Memphis, Vice President Darius Walker Jr. of Nashville, Secretary Judge Zachary Walden of Jacksboro and Treasurer Ashley Tipton of Nashville. The group also held its Annual Meeting and a CLE program on the State of DEI in the Legal Profession. The 2025-2026 Board met on Saturday for a wellness walk, committee planning sessions and its first board meeting.

On Friday evening, both the 2024-2025 and 2025-2026 boards met for dinner at Sperry's. They were joined by the YLD Fellows for the induction of new fellows and members of the DLI Class of 2025 for their graduation.

During the evening, outgoing president Sean Aiello presented a number of awards. The President's Award was given to Nashville attorney Patrick Morrison for his work on developing the YLD CLE Exploration Series and his tremendous efforts as the health and wellness coordinator. The Public Service awards were presented to Nashville attorney Ashley Tipton for her dedication to and expansion of the mock trial program; and Nashville attorney Alix Rogers and Judge Zack Walden for implementation of the YLD's first Rural Judicial Fellows (RJF) Program. Six board members also were recognized with Star of the Quarter Awards. They were Grace Burnett for service as District 8 representative, Billy Leslie for service as past president, Judge Alex McVeagh for service as president-elect, Jen Sneed for service as vice president, Amber Vargas for service as District 6 representative, and Kristen Walker for service as the Middle Tennessee CLE chair. See photos from the convention.

RITZ, Circuit Judge. The Board of Immigration Appeals denied Jin Yin Zhou discretionary relief from removal under 8 U.S.C. § 1227(a)(1)(H) and ordered her removed. Zhou filed an untimely motion to reopen her removal proceedings. In her motion, Zhou requested equitable tolling of the 90-day deadline and argued that her counsel provided ineffective assistance. The Board denied the motion, holding that Zhou failed to demonstrate the requisite prejudice and due diligence. Zhou seeks our review of those determinations. But because we lack jurisdiction over the Board’s lack-of-prejudice determination, and because that determination is dispositive of this appeal, we dismiss Zhou’s petition for review.

SUTTON, Chief Judge. Several hair stylists filed this lawsuit on the ground that their employer underpaid them by misclassifying them as independent contractors instead of employees. But an arbitration agreement stands in the way. The district court dismissed the claim in favor of arbitration. We affirm.

BLOOMEKATZ, Circuit Judge. Enbridge Energy owns and operates a pipeline that runs from Wisconsin, through Michigan, and into Canada. Between Michigan’s Upper and Lower Peninsulas, the pipeline crosses through the bottomlands of the Straits of Mackinac, land that belongs to the State of Michigan. Enbridge’s pipeline crosses the Straits pursuant to a 1953 easement between Enbridge and the State. In recent years, the pipeline has generated multiple lawsuits and media attention. This appeal stems from a case that began in 2020, when Michigan Governor Gretchen Whitmer informed Enbridge that the State was revoking the easement. Governor Whitmer alleged that Enbridge had violated the easement by allowing its pipeline to create an unreasonable risk of a catastrophic oil spill. In response, Enbridge filed suit in federal court against Governor Whitmer and Daniel Eichinger, the Director of the Michigan Department of Natural Resources, alleging that the Michigan officials’ actions violated federal law and requesting declaratory and injunctive relief prohibiting the defendants from interfering with the operation of the pipeline. This appeal concerns a narrow, threshold issue in this case: the defendants’ argument that Enbridge’s claims are barred by Eleventh Amendment sovereign immunity. Below, the district court rejected that argument. We do as well. We hold that Enbridge’s lawsuit falls within the Ex parte Young exception to Eleventh Amendment sovereign immunity and accordingly affirm the district court.

Gary Rollins, Defendant, was charged with one count of rape of a child and two counts of aggravated sexual battery ni September of 2020. At hte conclusion of the first trial, the jury found Defendant not guilty of rape of a child but could not reach a verdict on the lesser-included offenses of rape of a child. The jury could not reach a verdict on either count of aggravated sexual battery. The trial court granted a mistrial for the remaining lesser-included offenses of rape of a child and the two counts of aggravated sexual battery. In a second trial on the same presentment, Defendant was again tried for rape of a child. The jury found Defendant guilty of rape of a child and two counts of aggravated sexual battery. At sentencing, Defendant challenged the rape of a child conviction for the first time on the basis that it violated double jeopardy. The trial court agreed, entering a judgment for the lesser-included ofense of atempted rape of a child. The trial court sentenced Defendant ot twenty years for the attempted rape of a child conviction and fifteen years for each aggravated sexual battery conviction. The trial court ordered the sentences to run consecutively, for a total effective sentence of fifty years. On appeal, Defendant argues that the trial court abused its discretion by allowing the State to introduce evidence of a prior bad act ni violation of Tennessee Rule of Evidence 404(b), that his second trial for rape of a child violated his right against double jeopardy, and that the trial court had no authority to modify the conviction on the jeopardy-barred offense to attempted rape of a child. Because the Defendant failed to demonstrate a reasonable probability that he would not have been convicted of the attempted rape of a child absent the presence of the charge of rape of a child and because the trial court did not abuse its direction by allowing the State ot introduce evidence of a prior bad act, we affirm the convictions.

In this divorce, the trial court sanctioned Husband for failing to participate in discovery. After a final hearing at which Husband failed to appear, the trial court entered a final decree of divorce that awarded Wife monetary judgments and alimony, divided the marital property, adopted Wife’s proposed parenting plan, and set child support. Husband filed a motion to set aside, alter, or amend the final decree, which the trial court denied. On appeal, Husband challenges the sanctions and complains that the trial court failed to consider the statutory best interest factors when fashioning the permanent parenting plan. Although the trial court’s factual findings concerning the children’s best interest are deficient, we can “soldier on” by conducting a de novo review of the record to determine where the preponderance of the evidence lies. After that review, we affirm.

Following mediation, family members signed a settlement agreement resolving their business dispute. One party then sought to withdraw from the agreement. The trial court determined that the party’s ability to withdraw was limited and ordered him to close on the transactions contemplated by the agreement. Because we conclude that the settlement agreement’s language was ambiguous, we vacate and remand for an evidentiary hearing.

This appeal arises from an order requiring a petitioner to pay a filing fee or face dismissal of his case. Because the order is not final, we lack subject matter jurisdiction and must dismiss the appeal.

The Tennessee General Assembly adjourned its 114th session yesterday, following the passage of a $59.8 billion state budget that received bipartisan support, including reallocating approximately $180 million of funding from Gov. Bill Lee’s proposed budget amendment in order to fulfill their own legislative priorities.

The budget for Fiscal Year 2025-2026 that passed the General Assembly included $78 million for TennCare, $4.5 million to expand staffing and raise salaries within the attorney general’s office, and $37.5 million to replace the Tennessee College of Applied Technology (TCAT) campus in Robertson County. The budget also committed an additional $35.6 million to the Rainy Day Fund and $597 million in disaster-related expenditures, including funds for Hurricane Helene relief and local Federal Emergency Management Agency (FEMA) match requirements. Lawmakers also established a $42.5 million grant pool to support essential community organizations and services such as volunteer fire departments, EMS providers, senior centers, museums and the Second Harvest Food Bank.

The final budget preserved key initiatives from the governor’s original proposal, including $17 million to overhaul the state’s Indigent Representation Program, $1 billion for transportation infrastructure, $62.7 million for K–12 facility upgrades and $25 million in grants to attract new businesses and grow the state’s workforce, and $145.9 million in Education Freedom Scholarships. A controversial proposal that would have allowed Tennessee school districts to deny enrollment or charge tuition to noncitizen students has stalled for the year. HB793/SB836, which sought to challenge the landmark 1982 Supreme Court ruling Plyler v. Doe — guaranteeing all children access to free public education regardless of immigration status — was paused after lawmakers raised concerns about possible violations of federal law and financial consequences. Additionally, legislation seeking to implement a takeover of the Memphis-Shelby County School Board will be taken up next year, as House and Senate leadership could not reach an agreement on the bill.

Gov. Bill Lee thanked the General Assembly “for its partnership and continued commitment to responsible fiscal stewardship and innovation to improve the lives of the people we serve.”

Some Hamilton County residents are expected to be selected as sequestered jurors for the trial of three former officers accused of second-degree murder in the 2023 death of Tyre Nichols. About 150 people were seated for possible selection Wednesday morning in the lobby of the Hamilton County Courthouse, the Times Free Press reports. Those selected for jury service will begin their duties Sunday, and the trial is expected to last about two weeks. Former Memphis Police Department officers Tadarrius Bean, Demetrius Haley and Justin Smith are set to stand trial starting Monday in connection with the beating death of Nichols.