The indigent representation proposal from the Tennessee Administrative Office of the Courts (AOC) on behalf of the Tennessee Supreme Court addresses a number of challenges in the state's current system. One benefit of the proposal would be eliminating the use of court time to appoint attorneys for these cases. Under the plan, judges would be able to rely on the proposed "Office of Indigent Conflicts and Civil Counsel," which would assume responsibility for appointing lawyers in child welfare cases and criminal cases when the public defender has a conflict. In addition, the proposed "Indigent Representation Commission" would be charged with reviewing, developing and, where possible, implementing procedures to improve accountability and prevent misuse of the system. Learn more about the plan and indigent representation in Tennessee. 

JULIA SMITH GIBBONS, Circuit Judge. Plaintiff-Appellant Sault Ste. Marie Tribe of Chippewa Indians (the “Sault Tribe”) objects to the district court’s entry of the 2023 Great Lakes Fishing Decree (the “2023 Decree”). The Coalition to Protect Michigan Resources (the “Coalition”) mounted a similar challenge in a separate but related appeal. The 2023 Decree results from a three-year negotiation between seven sovereigns—the United States, the State of Michigan, the Bay Mills Indian Community, the Grand Traverse Band of Ottawa and Chippewa Indians, the Little Traverse Bay Bands of Odawa Indians, the Little River Band of Ottawa Indians, and the Sault Ste. Marie Tribe of Chippewa Indians (collectively, the “Tribes”)—to resolve their differences in the allocation, management, and regulation of fishing in the Great Lakes waters. It reflects a balance that the parties struck between preserving the Tribes’ treaty- reserved rights and preserving the fishery waters as an ecological resource. As the only party that refused to stipulate to the 2023 Decree’s entry, the Sault Tribe argued that the district court (i) lacked the jurisdiction to enter the 2023 Decree without its consent and (ii) failed to evaluate the decree’s tribal fishing regulations based on the rigorous standard set out in People v. LeBlanc, 248 N.W.2d 199 (Mich. 1976). In addition, the Sault Tribe raised 137 “specific” objections to the 2023 Decree’s provisions based on a more generalized assertion that the 2023 Decree unduly restricts its tribal rights under an 1836 treaty. The district court overruled all of the Sault Tribe’s objections and entered the 2023 Decree, thereby binding the Sault Tribe to the 2023 Decree’s terms. United States v. Michigan, 2023 WL 5444315, at *70 (W.D. Mich. Aug. 24, 2023). On appeal, we affirm the district court’s entry of the 2023 Decree.

MURPHY, Circuit Judge. The immigration laws list many reasons why an immigrant may not be admissible into the United States, but they also give the Attorney General discretion to waive some of these grounds for inadmissibility. See 8 U.S.C. § 1182(a)(9)(B)(v), (i)(1). To obtain this type of waiver, an immigrant must show “to the satisfaction of the Attorney General that the refusal of admission to such immigrant alien would result in extreme hardship” to a qualifying relative. Id. § 1182(a)(9)(B)(v); see also id. § 1182(i)(1). The Board of Immigration Appeals in this case held that Nuzaira Rahman had failed to establish the required hardship and thus denied her requested waivers. Rahman asks us to review the Board’s hardship conclusion. Yet the immigration laws broadly deprive us of jurisdiction to review these discretionary denials. See id. § 1252(a)(2)(B). Rahman responds that the laws allow us to review “questions of law” even in this waiver context. Id. § 1252(a)(2)(D). She adds that the Supreme Court has held that the Board’s hardship finding in a different context falls within this jurisdictional safe harbor. See Wilkinson v. Garland, 601 U.S. 209, 212 (2024). Unlike the hardship provisions in this case, though, the hardship provision in Wilkinson did not clarify that an immigrant must prove hardship “to the satisfaction of the Attorney General.” We must give effect to this language. It shows that Congress committed the hardship inquiry to agency discretion in the waiver context. We thus lack jurisdiction over the Board’s hardship conclusion and dismiss Rahman’s petition for review.

The U.S. 6th Circuit Court of Appeals is seeking comments on the reappointment of Randal S. Mashburn, bankruptcy judge for the Middle District of Tennessee, to a 14-year term that would begin on Jan. 12, 2026. Members of the bar and the public are invited to submit comments to be considered during the reappointment process. All comments will be kept confidential and should be mailed to Circuit Executive Marc Theriault, 503 Potter Stewart U.S. Courthouse, 100 East Fifth St., Cincinnati, Ohio 45202 or be submitted via email. All comments must be received no later than April 16. Contact the Office of the Circuit Executive at 513-564-7200 for more information. Read the full announcement from the court.

KAREN NELSON MOORE, Circuit Judge. This appeal concerns issues of standing and mootness in a putative class-action suit. According to Bradley Patton, state and local officials in Rutherford County, Tennessee unconstitutionally require pre-trial detainees to prove in a hearing before the state court that any bail funds equal to or in excess of $75,000 were not derived directly or indirectly from criminal activities. On June 13, 2023, Patton requested permission to post $100,000 to cover outstanding bail. Despite having the funds ready to secure his release, Patton was not released from custody. Under Rutherford County’s local rules, Patton had to wait for the state court to schedule a hearing to determine whether the bail money was sourced from any criminal activities. Patton filed this putative class action in federal court claiming that this local rule violated his and the putative class’s due-process and Eighth Amendment rights. For the reasons that follow, we REVERSE the district court’s judgment dismissing Patton’s claims on jurisdictional grounds and REMAND for proceedings consistent with this opinion.

CHAD A. READLER, Circuit Judge. Inspired by the Sentencing Commission’s retroactive amendment of a relevant guidelines provision, Kevin Obi asked the district court to reduce his sentence. The district court did so, but in an admittedly modest fashion: it reduced Obi’s 300-month sentence to 293 months. Obi challenges that outcome as procedurally and substantively unreasonable. We affirm.

KAREN NELSON MOORE, Circuit Judge. This § 1983 case concerns alleged constitutional violations in the investigation and prosecution of George Clark and Kevin Harrington. Clark and Harrington spent nearly two decades in prison before the Wayne County Prosecution Integrity Unit determined that they did not receive a fair trial because their murder convictions were secured based on the testimony of a singular eyewitness, who claimed she had been coerced to lie by detectives. Following dismissal of the charges and Clark’s and Harrington’s releases from prison, the men sued those detectives for violating their constitutional rights. After discovery, the district court granted in part and denied in part the detectives’ motion for summary judgment based on qualified immunity. Specifically, the district court denied qualified immunity on the men’s claims that the detectives fabricated the statement of the eyewitness, facilitated their prosecution without probable cause, and violated the Brady rule by withholding evidence that detectives threatened and offered benefits to key witnesses. The detectives filed an interlocutory appeal on the denial of qualified immunity. For the following reasons, we AFFIRM the district court’s denial of qualified immunity and REMAND for trial on the merits.

A Maury County jury convicted Destiny Diamond Baxter and Anthony Wayne Sheffield of first degree premeditated murder, attempted first degree murder, especially aggravated robbery, two counts of felony murder, and abuse of a corpse. Defendant Sheffield was also convicted of possessing a firearm with a prior conviction for a crime of violence and employing a firearm during the commission of a dangerous felony. The jury determined that both Defendants should serve life in prison without the possibility of parole for the homicide offenses. As for the remaining convictions, the trial court sentenced Defendant Baxter to an additional twenty-two years and sentenced Defendant Sheffield to a further thirty-five years. On appeal, both Defendants challenge whether the evidence is legally sufficient to support their convictions. Defendant Sheffield also argues that the trial court erred in denying his motion to sever the Defendants’ cases and admitting photographs of the homicide victim into evidence during the jury’s sentencing phase. Further, Defendant Sheffield argues that the trial court improperly sentenced him for the other convictions by failing to consider the risk and needs assessment, miscalculating the range, and imposing consecutive sentences beyond his life term. Upon our review, we conclude that a harmless error exists in failing to issue a limiting instruction as requested by Defendant Sheffield, and we also remand the judgments for correction of clerical errors. However, we respectfully affirm the judgments of the trial court in all other respects.

Defendant pled guilty in Williamson County to aggravated vehicular assault and three DUI counts. The trial court sentenced Defendant to six years in confinement. Defendant argues on appeal that her sentence is excessive and the trial court abused its discretion in denying alternative sentencing. After reviewing the record, the parties’ briefs, the applicable law, and oral arguments, we affirm the judgments of the trial court but remand for entry of corrected judgment forms as detailed in this opinion.

We do not reach the substantive issues because the trial court failed to make sufficient findings as required by Tennessee Rule of Civil Procedure 52.01. Vacated and remanded.