At its winter meeting last month, the TBA Board of Governors announced a vacancy in two board positions: West Tennessee Grand Division Governor (a one-year term) and 7th District Governor (a three-year term). The 7th District includes the counties of Benton, Carroll, Chester, Crockett, Decatur, Dyer, Fayette, Gibson, Hardeman, Hardin, Haywood, Henderson, Henry, Lake, Lauderdale, McNairy, Madison, Obion, Tipton and Weakley. To be considered for either of these positions, email a statement of interest and resume to TBA Executive Director Sheree Wright at barED@tnbar.org by March 3. The board will consider nominees at its March meeting. Read more about the 2026-2027 election on the TBA website.

Knoxville lawyer Mary Beth Maddox, a partner with Frantz McConnell & Seymour LLP, has been elected vice president of the Tennessee Bar Association (TBA). She will assume the role in June at the TBA’s Annual Convention and is scheduled to serve as president for the 2028–2029 bar year. A Tennessee native, Maddox has practiced law for more than 30 years, focusing on civil litigation, including labor and employment, workers’ compensation and tort matters. She earned her bachelor’s degree from the University of Virginia in 1991 and her law degree from the University of Tennessee (now Winston) College of Law in 1994.

Maddox has long been active in the TBA, previously serving on its Board of Governors as associate general counsel and as an East Tennessee governor. She is currently in her third year as the association’s treasurer and has also served two terms as co-chair of the TBA’s Leadership Law (TBALL) program, where she served several years as a Steering Committee member. She received the President’s Award in 2015 for her testimony on workers’ compensation legislation on behalf of the TBA before the General Assembly. Upon completing her year as vice president, Maddox will become president-elect in June 2027 and will assume the presidency the following year.

The IRS has extended the deadlines regarding key provisions of the SECURE 2.0 Act. The extended deadlines also apply to sections 2202 and 2203 of the CARES Act and section 302 of the Taxpayer Certainty and Disaster Tax Relief Act. A recent notice was sent by the agency to plan administrators pushing compliance from the end of 2026 to Dec. 31, 2027. The move stems from stakeholder concerns over ongoing regulatory developments and the absence of model language, instead relying on good-faith adaptation. Forbes has more.

The TBA Elder Law Section on Friday, March 20 will host a free webinar on identifying medical impairment in older drivers. Occupational therapist Cody Stoval, one of eight Certified Driving Rehabilitation Specialists in Tennessee, will offer insight and describe the process of reporting impaired drivers to the Tennessee Department of Driver Improvement. Don’t miss this opportunity to learn how common diagnoses could present in your practice, and how community resources can assist if driving retirement is necessary. Register now.

The TBA Criminal Justice Section and the Tennessee Council on Developmental Disabilities on Monday, March 23 will provide a free webinar focused on working with clients who have developmental disabilities. This primer will kick off a series of deeper discussions about topics regarding developmental disabilities and how these disabilities are considered in Tennessee courts. One hour of general CLE credit is available for a $50 processing fee. Learn more here.

READLER, Circuit Judge. While on supervised release, Deldrick Spence was charged with a host of drug offenses as well as being a felon in possession of a handgun. With the district court’s permission, Spence represented himself at his subsequent revocation hearing. There, the district court revoked Spence’s supervision and imposed a 24-month term of imprisonment. On appeal, Spence primarily challenges the validity of his waiver of counsel and the procedural reasonableness of his sentence. As the district court did not err in allowing Spence to proceed pro se and did not consider impermissible sentencing factors in imposing a within- Guidelines sentence, we affirm.

MURPHY, Circuit Judge. The police learned of Leron Liggins’s drug distribution after intercepting his coconspirator’s calls. Liggins moved to suppress the evidence derived from these calls based on a defect in the underlying wiretap application. But the federal wiretap laws allow only an “aggrieved person” to file such a motion. They define “aggrieved person” as “a person who was a party to any intercepted wire, oral, or electronic communication or a person against whom the interception was directed[.]” 18 U.S.C. § 2510(11). Courts disagree over this definition’s scope. Some read it to adopt the Fourth Amendment’s standing rules, which grant standing to those who participated in an intercepted call or who owned the property from which the call occurred. Others interpret it to reach the “targets” of a wiretap application too. Liggins asks us to adopt the broader view. At day’s end, though, we need not choose between the two approaches because Liggins would not qualify as an “aggrieved person” either way. He did not participate in the intercepted calls, the calls did not use his cellphone or occur at his home, the wiretap application did not identify Liggins as a “target” of the investigation, and no evidence suggests that he was otherwise an unnamed target. We thus affirm.

KAREN NELSON MOORE, Circuit Judge. Plaintiff Jennifer Kilnapp brought this action against Defendants Bailey Gannon and the City of Cleveland, alleging in relevant part that Gannon used excessive force against her in violation of her Fourth Amendment rights when he shot her while the two were on duty as City of Cleveland police officers. Gannon intentionally fired his weapon in response to the threat posed by a suspect. He did not specifically intend to shoot Kilnapp. But that latter fact is immaterial to the question of whether Kilnapp was seized. We hold today that when an officer intentionally shoots their firearm in circumstances that objectively manifest an intent to restrain, any individual struck by the bullet is thereby seized, regardless of whether that individual was the officer’s specific intended target. Because this law was not clearly established at the time of Kilnapp’s shooting, however, we conclude that Gannon is entitled to qualified immunity on Kilnapp’s Fourth Amendment claim. We therefore VACATE the decision of the district court and REMAND for further proceedings.

Defendant, Lerico Sullivan, challenges the revocation of his probation, arguing that because the only evidence supporting the revocation was improperly admitted testimonial hearsay, this court should reverse and dismiss the revocation proceeding. Defendant also challenges the trial court’s holding him in contempt twenty times during the hearing and ordering the ten-day sentences imposed for each contempt finding to be served consecutively. The State concedes that the trial court erred by admitting testimonial hearsay but asks this court to remand the case for a new revocation hearing. The State contends that the trial court did not err by holding Defendant in contempt or by aligning the sentences consecutively. Because the trial court erred by admitting testimonial hearsay without making the appropriate findings and because no other evidence supported the allegations that Defendant violated his probation, we reverse the revocation of his probation and dismiss the case. Regarding the twenty findings of contempt and related consecutive sentencing decision, we conclude that the evidence preponderates against three of the findings of contempt and reverse and dismiss those findings. We also conclude that the effective sentence on the contempt convictions should be modified to sixty days to be served in confinement. Accordingly, the judgment of the trial court is affirmed as modified in part and reversed and dismissed in part.

A jury convicted the Defendant, David Keith Gunn, of one count of possessing fifteen grams or more of fentanyl for resale, one count of possessing a firearm during the commission of a dangerous felony, one count of being a felon in possession of a firearm, and one count of possessing drug paraphernalia. The Defendant also pleaded guilty to one count of driving on a suspended license with prior convictions. The trial court sentenced the Defendant to an effective term of incarceration of seventeen years for these offenses. In this appeal as of right, the Defendant contends that the trial court committed reversible error by denying his motion to suppress the evidence upon which his trial convictions are based. We find no error and affirm the judgments of conviction.