THAPAR, Circuit Judge. Prisoners often have complaints about prison life. When these complaints arise, prisoners can’t go straight to federal court. The Prison Litigation Reform Act (“PLRA”) requires prisoners to seek relief from state prison officials before filing a federal lawsuit. This is called an “exhaustion” requirement since prisoners must exhaust their administrative remedies before suing. “We are not insensitive to the challenges faced by the lower federal courts in managing their dockets and attempting to separate, when it comes to prisoner suits, not so much wheat from chaff as needles from haystacks.” Jones, 549 U.S. at 224. But policy concerns about the strength of the PLRA’s exhaustion requirement don’t justify displacing Michigan’s valid tolling rule and departing from the federal courts’ usual practice of borrowing state tolling rules. Finding an inconsistency here “cannot fairly be viewed as an interpretation of the PLRA.” Id. at 216. We reverse.

The Defendant, Marlos LeKeith Tipton, appeals from his convictions for vehicular homicide and speeding following a bench trial. Specifically, the Defendant contends that he was deprived of a fair trial based on the trial court’s denial of funding for a defense expert in vehicle collisions. He further argues that the proof was insufficient to support his conviction of vehicular homicide based upon reckless conduct predicated on excessive speed alone. After review, we affirm the judgments of the trial court.

A Davidson County jury convicted the Defendant, Damon Cordell Parson, of three counts of selling .5 grams or more of cocaine, and the trial court sentenced him to a total effective sentence of twelve years, to be served consecutively to a previous sentence. On appeal, the Defendant contends that the trial court erred when it admitted audio recordings of the drug transactions and that, without the recordings, the evidence is insufficient to convict him. He further contends that the trial court erred when it sentenced him because it improperly sentenced him to the maximum sentence within his applicable sentencing range and did not make proper considerations with regard to alternative sentencing. After review, we affirm the trial court’s judgments.

State legislative committees met recently to consider special session proposals. Gov. Bill Lee’s Education Freedom Act of 2025 (SB6001/HB6004) passed out of the House and Senate Education Committees as amended and is expected to be on the House and Senate floors on Thursday, the Nashville Post reports. The move came after President Donald Trump spoke publicly in support of the initiative. During committee consideration, an amendment was added to specify that $77 million in the bill for school infrastructure would first be used to bolster the HOPE scholarship if a shortage occurs in that fund. The amendment also specifies that infrastructure funds would go first to schools in economically distressed or at-risk counties, followed by those that are high-performing and then those in fast-growth areas. House and Senate committees also considered immigration legislation (SB6002/HB6001). Funding for local governments that agree to crack down on undocumented immigrants was reduced from $20 million, as proposed by the governor, to just more than $5 million. In addition, state Sen. Todd Gardenhire, R-Chattanooga, split from his party to oppose a provision charging local elected officials with a felony if they support sanctuary city laws. Gardenhire called the provision a slippery slope and argued that elected officials should not be punished for taking a political stance. The amended bill passed the Senate with a vote of 26-7; the House is scheduled to vote tomorrow. The Nashville Banner has more on this bill.

A Knox County jury convicted the Petitioner, James Theodore Menard, of one count of rape of a child, one count of exhibition of pictures depicting sexual conduct harmful to a minor, and two counts of aggravated sexual battery. The trial court imposed an effective sentence of forty-two years in the Tennessee Department of Correction. On appeal, this court affirmed the trial court, and our supreme court denied review. State .v Menard, No. E2021-00164-CCA-R3-CD, 2022 WL 1498767, at *1 (Tenn. Crim. App. May. 12, 2022), perm. app. denied (Tenn. Sept. 9, 2022). The Petitioner filed for post-conviction relief, alleging ineffective assistance of counsel. After a hearing, the post-conviction court denied relief. On appeal, the Petitioner maintains that his attorney was ineffective for failing to disclose a plea offer and failing to review discovery. After review, we affirm the post- conviction court's judgment.

This is an appeal from a final order entered on September 20, 2024. The envelope within which the notice of appeal was mailed reflects that it was mailed from the prison mailroom of the facility where the appellant was incarcerated on November 9, 2024, more than thirty days from the date of entry of the order from which the appellant is seeking to appeal. Because the notice of appeal was not timely filed, we have no jurisdiction to consider this appeal.

This is an accelerated interlocutory appeal as of right pursuant to Tennessee Supreme Court Rule 10B § 2.02 from the trial court’s denial of a motion for recusal. We have determined that the petition must be summarily dismissed due to substantive failures to comply with Rule 10B. Accordingly, the appeal is dismissed.

This appeal arises from the dismissal of a health care liability action. The plaintiff’s husband passed away after a complication that occurred during a medical procedure. The plaintiff provided pre-suit notice of her claim to five health care providers but ultimately filed suit against only three of the providers. The plaintiff voluntarily dismissed her initial action, but then she re-filed it within a year. The defendants filed a motion to dismiss the re-filed suit, alleging that the plaintiff failed to substantially comply with the requirements of Tennessee Code Annotated section 29-26-121. The trial court granted the motion to dismiss after finding that the plaintiff failed to substantially comply with section 29-26-121(a)(2)(E) due to limiting language included in HIPAA authorizations she had provided to the defendants. The trial court also found that the plaintiff failed to substantially comply with section 29-26-121(a)(4), which requires plaintiffs to file certain documentation with their complaint. We hold that the trial court erred in finding that the plaintiff failed to comply with section 29-26-121(a)(4) but did not err in finding that the plaintiff failed to comply with section 29-26-121(a)(2)(E). Accordingly, the judgment of the trial court is affirmed in part and reversed in part.

Mark Gray ("Employee") reported injuries after falling from a ladder while working for Tyson Foods, Inc. ("Employer"). The claim was accepted as compensable, and the parties entered into a settlement agreement providing permanent partial disability benefits. After the initial compensation period ended, Employee filed a petition for increased benefits. Following a hearing, the Court of Workers' Compensation Claims ("trial court") denied the request for increased benefits. The Workers' Compensation Appeals Board ("Appeals Board") affirmed. Ernployee has appealed, and the appeal has been referred to the Special Workers' Compensation Appeals Panel pursuant to Tennessee Supreme Court Rule 51. We affirm the judgment of the Appeals Board and adopt its opinion as set forth in the attached Appendix.

The American Bar Association (ABA) 2025 Midwinter Meeting kicks off tomorrow in Phoenix, Arizona. On Saturday, the TBA will host a reception honoring Belmont College of Law Dean Alberto Gonzales. On Monday, the ABA House of Delegates will consider over two dozen policy matters, including resolutions on judicial security, lawyer well-being, antisemitism education and wrongful convictions according to a news release. Among the proposals are resolutions urging bar associations to support enhanced judicial security, protection for government officials' personal information and limiting alleged "judge shopping" in federal cases. The meeting will be presided over by Tennessee lawyer Jonathan Cole, chair of the House of Delegates, with remarks from Arizona Gov. Katie Hobbs, ABA President Bill Bay and others. The ABA Young Lawyers Division also will meet and consider resolutions promoting lawyer well-being, prosecutorial efforts to correct wrongful convictions, Holocaust studies in schools and efforts to narrow the scope of questions during the bar admission process.