Memphis attorney Robert Miles Mason Sr. died Feb. 1 at age 61 after a long battle with cancer. He received his law degree from the University of Memphis Cecil C. Humphreys School of Law in 1994. A Memphis native, Mason founded Miles Mason Law Group PLC and was a certified public accountant. Mason served on the Tennessee Bar Journal's Editorial Board from 2003-2006 and as chair of the TBA's Family Law Section. He received the Justice Joseph W. Henry Award for Outstanding Legal Writing in 2024 for his article “You Are the Father!: Untangling Custody Rights in Tennessee Between Unmarried Parents,” which appeared in the November/December 2023 issue of the Journal. Mason’s father-in-law, the late Judge Joe B. Jones, was the first recipient of the award in 1981. A funeral Mass was held Feb. 9.  In lieu of flowers, donations may be made in Mason's name to Christian Brothers High School or the Orpheum Theatre Group.

Carleton “Carl” Edward Knechtel, 86, of Dallas, Texas, died Jan. 23. Born in Fortaleza, Brazil, to missionary parents, he held triple citizenship at birth by virtue of being born in Brazil to a Canadian father and American mother. After a varied 20-year career, Knechtel received his law degree from University of Tennessee (now Winston) College of Law in 1971. He worked for more than 31 years as an attorney in the IRS Office of Chief Counsel for the Criminal Tax Division, initially in Chicago for 15 years and then in Dallas for 16 years. Following his retirement from public service in 2003, Knechtel practiced law in the Dallas area on a limited basis and served as an expert witness in criminal tax trials. In lieu of flowers, donations may be made in Knechtel's memory to the Salvation Army or a local food bank.

On Feb. 17, the Tennessee Supreme Court suspended Loudon County attorney William Anthony Paxton from the practice of law for one year, with the entire suspension stayed if Paxton refrains from further misconduct and complies with a Nov. 25, 2025, order from the Supreme Court of Ohio. On Jan. 7, the Tennessee Supreme Court entered a notice of reciprocal discipline directing Paxton to demonstrate why it should not impose the same discipline imposed by the state of Ohio. The court notes that Paxton did not respond to its order. He also must comply with requirements regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

The Tennessee Supreme Court permanently disbarred Knox County attorney Darren Vincent Berg from the practice of law on Feb. 17. The court also ordered Berg to pay restitution of $65,000 to two former clients. The court determined that in 11 separate matters, Berg engaged in ethical misconduct that involved failure to provide competent representation, act within the scope and authority communicated by clients, act with reasonable diligence, communicate with clients, properly terminate representation, expedite litigation, and provide legal services after accepting substantial fees. The court also found that he charged unreasonable fees, engaged in conflicts of interest, knowingly relied on non-meritorious claims, made false statements to courts and parties, engaged in improper communication with represented parties, engaged in the unauthorized practice of law after suspension of his license, repeatedly abandoned clients and their cases, and engaged in conduct involving deceit or dishonesty and prejudice to the administration of justice. These actions violated Rules of Professional Conduct 1.1, 1.2, 1.3, 1.4, 1.5, 1.7, 1.16, 3.1-3.5, 4.2, 4.4, 5.5, 8.1 and 8.4(b) – (d).

READLER, Circuit Judge. Tawsif Mohammed Tajwar was sentenced to serve 90 months in prison due to his conviction for money laundering. Tajwar believed that later developments at the Sentencing Commission gave him a basis to request a retroactive sentence reduction, which he did. The district court denied his request, concluding that Tajwar’s possession of a firearm in connection with his money laundering offenses made him ineligible for relief. Seeing no error in the district court’s holding, we affirm.

BOGGS, Circuit Judge. David Myrie appeals his conviction under 8 U.S.C. § 1326 for unlawfully reentering the United States after prior removals. He claims that § 1326, a facially race-neutral law, violates equal protection under the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latino immigrants. He argues that the statute’s predecessor—the Undesirable Aliens Act of 1929—was enacted with discriminatory intent,1 and that § 1326, first codified as part of the Immigration and Nationality Act (INA) of 1952 and amended several times thereafter, perpetuates that taint because Congress failed to affirmatively repudiate the racist intent of the 1929 Act. Eight of our sister circuits have addressed similar constitutional challenges to § 1326 and all have rejected them.2 For the reasons set forth below, so do we.

MURPHY, Circuit Judge. Kevin Hamm says that his coworkers at Pullman SST, Inc., ridiculed him for months after they learned he was bisexual. When Hamm formally reported this abuse, an HR employee interviewed nine of his coworkers. All nine denied harassing Hamm or witnessing harassment. Although the HR employee could not corroborate Hamm’s claims, she still decided to require all employees to review Pullman’s antidiscrimination policy as a preventative measure. She also agreed to transfer Hamm to a new worksite and allowed him to take medical leave. While on leave, though, Hamm raised concerns with all the alternative assignments offered to him. Pullman thus terminated Hamm. He sued Pullman under Title VII and Michigan law, claiming that the alleged abuse created a hostile work environment and that the termination was in retaliation for his sexual-harassment complaint. The district court rejected both claims at the summary-judgment stage. It correctly held that Hamm could not hold Pullman liable for the abuse because it took proper actions upon learning of his allegations. And it correctly held that Hamm did not present enough evidence to show that Pullman’s reason for ending their relationship (his refusal to accept any other job assignment) was pretext for discrimination. We thus affirm.

Defendant Imari C. Glover robbed a Cash Express with help from his then-girlfriend, Shelby Beam. He pleaded guilty to Hobbs Act robbery. Eleven days after signing his plea agreement, an image of a rat in the crosshairs of a riflescope was posted on his Facebook profile. At sentencing, the district court enhanced Glover’s Guidelines range because the robbery involved a “financial institution,” as contemplated in the Guidelines, and because Glover acted in a leadership role when carrying out the robbery. The district court denied Glover an acceptance of responsibility reduction because of the rat picture. Glover was sentenced to 188 months’ imprisonment—the top of his Guidelines range. On appeal, Glover argues that the Cash Express is not a “financial institution” under the Guidelines and that he did not lead the robbery. He further argues that his plea agreement entitled him to an acceptance of responsibility reduction and that his sentence is substantively unreasonable. We disagree and affirm.

This is a termination of parental rights case. The trial court denied Appellant’s 11th motion to recuse, and Appellant filed an interlocutory appeal as of right pursuant to Tennessee Supreme Court Rule 10B. Discerning no error, we affirm.

A municipal court determined that property owners repeatedly violated a city zoning ordinance restricting vacation rentals in residential areas. The property owners appealed to circuit court, where the matter was consolidated with another action filed by the City against the property owners in which the City was seeking a declaratory judgment and injunctive relief. The circuit court found the property owners in violation of the zoning ordinance and granted a declaratory judgment and a permanent injunction, and affirmed the municipal court’s rulings as to the violations. The property owners appeal. In doing so, they advance numerous issues challenging the circuit court’s rulings. While significant briefing deficiencies result in the waiver of the majority of these issues, in considering the issues that are properly before this court, we conclude that the trial court erred in its interpretation of the ordinance. However, because our decision does not fully resolve whether the property owner violated the ordinance, we remand for further proceedings.