THAPAR, Circuit Judge. Raymond Erker operated a Ponzi scheme that swindled over fifty people, mainly senior citizens, out of nine million dollars. A jury convicted Erker of mail fraud, wire fraud, money laundering, and making a false statement under oath. Erker appeals his money laundering conviction, raises an ineffective-assistance-of-counsel claim, and objects to various aspects of his sentence. Erker’s arguments fall short, so we affirm his sentence. But we remand so that the district court can consider one of Erker’s sentence-reduction arguments. ying any rule, he didn’t have enough clean funds to make his withdrawals. And we reject Erker’s sufficiency-of-the-evidence challenge to his § 1957 conviction, his sentencing objections, and his ineffective-assistance-of-counsel claim. We affirm Erker’s sentence and remand for consideration of his eligibility for a sentence reduction under Amendment 821.

GRIFFIN, Circuit Judge. This case returns to us after the Supreme Court vacated our earlier decision and remanded for our reconsideration following Erlinger v. United States, 602 U.S. 821 (2024). After defendant Calvin Cogdill pleaded guilty to being a felon in possession of a firearm, the district court, over Cogdill’s objection, determined that Cogdill committed three prior drug offenses “on occasions different from one another,” subjecting him to an enhanced sentence under the Armed Career Criminal Act. Erlinger later clarified that it was error for the judge, instead of a jury, to make that occasions decision. Here, we must review that error for harmlessness, see United States v. Campbell, 122 F.4th 624, 629–31 (6th Cir. 2024), and we hold that the district court’s error was not harmless. We thus vacate Cogdill’s sentence and remand to the district court for further proceedings consistent with this opinion.

COLE, Circuit Judge. A district court sentenced Sardar Ashrafkhan for conspiring to distribute and possess with intent to distribute a controlled substance, conspiring to commit health care fraud, and money laundering. After a retroactive amendment to the United States Sentencing Guidelines, Ashrafkhan moved for a sentence reduction under 18 U.S.C. § 3582(c)(2). To be eligible for the reduction, a defendant must meet ten criteria, including showing that “the defendant did not receive an [aggravating role adjustment] and was not engaged in a continuing criminal enterprise[].” USSG Amend. 821, Pt. B; § 4C1.1(a)(10). Since Ashrafkhan received an aggravating role adjustment, the district court determined he was ineligible and denied his motion. Ashrafkhan appeals, arguing he meets the criteria despite the aggravating role adjustment because he did not engage in a continuing criminal enterprise. We affirm.

In this interlocutory appeal, at issue is the appropriate jury instruction to be given in a murder case for a crime committed in 2015 but tried in 2024. In the time between the murder and trial, the Tennessee Supreme Court released an opinion, State v. Thomas, 687 S.W.3d 223 (Tenn. 2024), which abrogated the old common-law accomplice-corroboration rule. The State requested the new jury instruction pursuant to Thomas, and the trial court ruled that fairness concerns required the old common-law instruction. The State sought and obtained an interlocutory appeal. On appeal, it asserts that the trial court erred and that the jury should be instructed pursuant to Thomas. After review, we conclude that the Thomas court intended that the new law apply to trials commencing after March 7, 2024. Because the trial for this matter has not yet commenced, the jury in this case shall be instructed in accordance with Thomas and its conclusion regarding the jury instruction about accomplice testimony. Accordingly, the order of the trial court is reversed, and this case is remanded for further proceedings consistent with this opinion.

The U.S. Treasury Department has announced it will not enforce a March 21 deadline for most businesses to report ownership information required by the Corporate Transparency Act, the Nashville Business Journal reports. The act, passed by Congress in 2021, has been the subject of ongoing court battles that have created a shifting set of guidelines and deadlines. Most recently, in January, the U.S. Supreme Court allowed the reporting mandate to take effect. On March 2, the department said it would not enforce the upcoming compliance deadline or issue fines for businesses that do not report the information. Instead, it said it will go back to the rule-making process to "narrow the scope of the rule" to apply to foreign companies only.

February 24, 2025 - February 28, 2025.

The indigent representation proposal from the Tennessee Administrative Office of the Courts (AOC) on behalf of the Tennessee Supreme Court is expected to provide a range of benefits. These include increasing the number of attorneys willing to accept appointments, enhancing the quality of representation with training and mentorship opportunities, focusing on complex cases and smaller rural communities to build capacity, and eliminating the need for judges to find attorneys to take cases. The plan also is expected to lead to more timely representation and better outcomes for children needing guardian ad litem services, and a smoother process in adoption cases. In addition, it will assist in the proper determination of indigency by developing processes and safeguards to protect against misuse. The TBA applauds the collaborative efforts of the Supreme Court, the AOC and stakeholders in developing and advocating for a new plan moving forward. Learn more about the plan and indigent representation in Tennessee.

Author and past TBA Convention speaker Elaine Weiss will share insights from her new book “Spell Freedom: The Underground Schools That Built the Civil Rights Movement” at an event in Nashville this week. She will speak with community relations expert Joyce Searcy on Thursday at 6:30 p.m. CST at the Nashville Public Library, 615 Church St., Nashville 37219. The event is being held in conjunction with Parnassus Books, Fisk University, American Baptist College and Tennessee League of Women Voters. Tickets are required. A portion of proceeds will benefit the Nashville Public Library Foundation.

Several wrongful death lawsuits recently have been filed across the state. In Memphis, the mother of Shelby County Jail inmate Ramon McGhee — who died malnourished and covered in bed bugs — has filed a lawsuit against the county and its jail health care provider, the Commercial Appeal reports. In Chattanooga, the son of a man beaten to death in 2018 at the McMinn County Jail has filed a $25 million wrongful death suit. Gavin Cook says that "deliberate indifference" by the county sheriff led to his father Timothy Brian Cook’s death, according to the Times Free Press. And in Knoxville, a court has ruled that a suit can proceed against three police officers in the shooting death of Anthony Thompson. That case alleges the officers failed to provide medical care to Thompson after he was shot by police. The appellate decision reverses a lower court ruling that the officers could not be sued personally, Knox News reports.

The NAACP Legal Defense Fund has sued Fayette County over its 2021 electoral map. The suit alleges that the map adopted by commissioners was chosen “at least in part with the intent to racially discriminate against Black voters” and that the decision was made against the advice of the commission’s redistricting committee and legal counsel. The filing comes after the U.S. Justice Department sued the Fayette County Board of Commissioners in January, similarly alleging the board violated the Voting Rights Act when it adopted the redistricting plan. Tennessee Lookout has more on the suit and a copy of the filing.