The Tennessee Board of Professional Responsibility (BPR) has issued two new ethics opinions. The first, 2025-F-171, addresses the ethical propriety of a non-disparagement clause in a products liability case settlement agreement that makes the lawyers in Firm A parties to the settlement proposed by Firm B. The second, 2025-F-172, addresses limited scope legal services provided by a private attorney. That opinion states that attorneys may engage in limited scope representation so long as it is reasonable under the circumstances and the client gives informed consent, preferably in writing. Attorneys also must follow the Tennessee Rules of Civil Procedure, specifically Rule 11.0l(b) and (c) regarding disclosure of such limited scope representation. See all past opinions from the board. Update: On April 21, 2025, the Board of Professional Responsibility voted to withdraw formal ethics opinion 2025-F-172.

The Tennessee Supreme Court on March 26 directed the Board of Board of Professional Responsibility to respond to a filing by California lawyer Dale Gerard Nowicki that discipline imposed against him by the California Supreme Court should not be imposed in Tennessee. The court directed Nowicki to explain why reciprocal discipline should not imposed. He responded on March 10, arguing that identical discipline should not be imposed in Tennessee. The court directed the BPR to file its response by April 23.

Mississippi lawyer Carlos Eugene Moore was suspended from the practice of law in Tennessee on March 27 after being suspended by the Supreme Court of Mississippi on Dec. 31, 2024. The reciprocal discipline was imposed after the Tennessee Supreme Court reviewed Moore’s response to its Feb. 25 order directing him to demonstrate why the discipline imposed in Mississippi should not also be applied in Tennessee.

The Tennessee Supreme Court permanently disbarred Knox County attorney Douglas A. Trant from the practice of law on March 26. Trant was retained by clients in two separate matters to potentially pursue specific legal objectives that were dependent on the outcome of initial research to establish whether they had viable causes of action. In both cases, Trant accepted a fee to conduct initial research, performed only minimal legal research, and discovered that neither client had a meritorious claim or viable cause of action. However, he falsely stated to each client that their cases had merit and accepted more substantial fees to initiate litigation. He took no further action. He never filed a complaint or initiated litigation, ceased all communication, failed to refund the unearned fees, failed to return client files, and abandoned his clients and their cases. These actions were determined to violate Rules of Professional Conduct 1.3, 1.4, 1.5, 1.16 and 8.4.

On March 26, the Supreme Court of Tennessee suspended Hawkins County lawyer Gerald Todd Eidson from the practice of law for two years with one year to be served on active suspension and the remainder on probation so long as Eidson engages a practice monitor. The court took the action after determining that Eidson failed to provide competent representation to a client, failed to act with reasonable diligence and promptness during his representation of the client, and failed to inform the Juvenile Court of an earlier misrepresentation regarding the incarceration status of the client, which resulted in prejudice to the administration of justice. His actions were determined to violate Rules of Professional Conduct 1.1, 1.3 and 8.4(d).

Shelby County lawyer Samuel John Muldavin has received a public censure from the Tennessee Supreme Court. In representing two clients in defense of a detainer action, the court found that Muldavin failed to communicate adequately with clients, had no prior experience handling residential landlord tenant matters and did not complete any research of applicable law or otherwise take any action to prepare for trial. He also agreed to the scheduling of trial for calculation of money damages, fees and costs, despite the inadequacy of service of process. His actions were determined to violate Rules of Professional Conduct 1.1, 1.2(a), 1.3, 1.4, 1.5(b) and 3.3(a)(1).

The Tennessee Supreme Court on March 20 suspended 11 attorneys for failure to pay the annual registration fee; six of them also failed to file proof that client funds are held in an IOLTA-compliant account. View the fee suspension order and IOLTA suspension order. Recent reinstatements for fee or IOLTA violations include three in 2024. See the list of all lawyers suspended and reinstated for fee and IOLTA violations in 2025 or access all administrative suspensions dating back to 2005.

Gibson County lawyer Eric Preston Egbert received a public censure from the Tennessee Supreme Court on March 14. The court took the action after finding that he engaged in activity that involved a conflict of interest in violation of Rule of Professional Conduct 1.7, 1.9(c) and 8.4(d) and (e). Egbert agreed to represent two individuals in probating the estate of their brother. The principal asset was a parcel of realty located in the county. The clients subsequently decided not to proceed with the probate action, and Egbert closed his file. Some time later Egbert was hired as the delinquent tax attorney for the county. In this capacity, he learned of delinquent taxes on the property and contacted the former clients with an offer to purchase the land. No sale took place, but the court found that the action created a concurrent conflict of interest between Egbert’s role as a real estate investor and as delinquent tax attorney. The court announced the censure on March 24.

On March 12, the Tennessee Supreme Court dismissed a petition for discipline without prejudice against Hawkins County lawyer Terry Risner and struck a notice of submission filed by the board. The court reports that the Board of Professional Responsibility filed a notice to dismiss and withdrawal of notice of submission on March 11. The board had filed a petition for discipline with the court on July 31, 2024. Risner remains suspended based on a March 22, 2024, order.

The Tennessee Supreme Court has directed Dale Gerard Nowicki to respond within 30 days why discipline imposed in the state of California should not also be imposed in Tennessee. On Jan. 6, the California Supreme Court imposed two years of probation on Nowicki. The Tennessee court noted in its order that if Nowicki does not respond by the deadline, it will impose discipline "with identical terms and conditions" than what was imposed in California.