Electronic voting in TBA's election for vice president will close Feb. 13 at 11:59 p.m. CST. TBA members were sent an email on Jan. 30 with a ballot for the two candidates running for TBA vice president. The email was sent from Intelliscan Inc. Members also were sent an email with profiles of the two candidates running for vice president. That email was sent from elections@tnbar.org. If you did not receive either email in your inbox, please check your spam folder. If either email indeed was not received, please contact elections@tnbar.org to request that the missing email(s) be resent. The candidate profiles also are available on the TBA website. (An earlier version of this item in TBA Today listed the incorrect time for submitting ballots.)

The Tennessee Alliance for Black Lawyers (TABL) and the Tennessee Bar Association Young Lawyers Division's (YLD) Diversity Committee will hold a networking mixer on Feb. 20. The free event will run from 5:30-7:30 p.m. EST at Blue Orleans Seafood Restaurant, 1463 Market St., Chattanooga 37402. Special thanks to Geeter Law Office PLLC for sponsoring this event. All are welcome but an RSVP is required by Feb. 13. See a flyer for more information.

KAREN NELSON MOORE, Circuit Judge. Thomas O’Hara filed for Chapter 13 bankruptcy. At a hearing on the United States Trustee’s motion to dismiss, the bankruptcy court made clear its intent to convert the case to Chapter 7. But O’Hara did not move to dismiss his Chapter 13 case until after the bankruptcy court had entered its conversion order. The bankruptcy court denied both that motion to dismiss and O’Hara’s subsequent Rule 60(b) motion. The district court affirmed in its appellate capacity. For the reasons explained below, we hold that we have jurisdiction and AFFIRM the decision of the district court.

JOHN K. BUSH, Circuit Judge. In this appeal, we consider whether a district court can remand a case to the Social Security Administration (SSA) under Sentence Four of 42 U.S.C. § 405(g) without explicitly affirming, modifying, or reversing the decision of the Administrative Law Judge (ALJ) to deny a claimant benefits. We hold that it cannot, so we VACATE the district court’s decision and REMAND for further proceedings not inconsistent with this opinion.

THAPAR, Circuit Judge. Clarence Borns was convicted in Michigan state court of committing assault with intent to murder and illegally possessing a gun. He then filed a habeas corpus petition in federal court, claiming that his attorney was ineffective because he failed to investigate and present crucial witness testimony. But Borns filed his petition over a year after the limitations period expired. And he hasn’t identified a reason to excuse his lateness. So we reverse the district court’s conditional grant of Borns’s habeas petition.

The pro se Petitioner, Dexter Parker, appeals the denial of his petition for post-conviction relief, arguing that he received the ineffective assistance of trial counsel. Based on our review, we affirm the judgment of the post-conviction court.

Marina Kotova (“Plaintiff”) and Thomas Kevin True (“Defendant”), who were formerly married, entered into an agreement whereby Defendant would purchase certain real property owned by Plaintiff pursuant to an installment purchase agreement. The agreement provided that, in the event of a default by Defendant, Plaintiff could sue for monetary damages, specific performance, or both. Additionally, an addendum to the agreement allowed Plaintiff to evict Defendant from the property if he was in default for more than thirty days. Defendant defaulted, and Plaintiff sued him seeking possession of the property and monetary damages. The trial court instead awarded Plaintiff specific performance, which required Plaintiff to sell the property to Defendant upon Defendant curing his default. Plaintiff appeals the trial court’s award of specific performance. We find that the trial court erred by awarding Plaintiff a remedy other than what she requested, and we reverse the trial court.

In this case involving termination of a mother’s parental rights to her child, the trial court allowed the mother’s counsel to withdraw from representation at the beginning of trial when the mother did not appear. On appeal, the mother asserts that she did not have prior notice of the trial date and that her attorney did not provide her with notice of an intent to withdraw from representation. Based on the circumstances presented and applicable law, we vacate the trial court’s termination of the mother’s parental rights and remand for a new trial.

The employer avers the trial court erred in finding the employee was likely to prove at trial that he provided timely notice of an alleged gradual injury and in awarding medical benefits in this interlocutory appeal. The employee began having low back pain after being assigned additional work duties and sought medical care on his own, including physical therapy. Following his termination from the employer, the employee’s primary care physician referred him for an MRI. The employee filed a petition for benefit determination fifteen days after the referral, and the employer denied the claim for lack of timely notice. By the time of the expedited hearing, the employee had obtained a medical opinion from a neurosurgeon recommending surgery and opining that the injury and need for surgery were primarily caused by the employee’s gradual work injury. The employer obtained a records review from a pain management specialist, who opined the employee’s herniated discs were likely degenerative in nature. Following an expedited hearing, the trial court found the employee was likely to be successful at a trial in proving he gave timely notice of a work-related injury, credited the employee’s expert over the employer’s expert as to causation, and ordered the employer to provide a panel. The employer has appealed. Having carefully reviewed the record, we affirm the trial court’s order and remand the case.

Tennessee Department of Correction (TDOC) officials are seeking $1.7 million for drone detection technology to prevent contraband from being airdropped into state prisons, the Nashville Banner reports. TDOC Commissioner Frank Strada discussed the request Tuesday during a budget hearing with the Senate State and Local Committee. Strada said the technology would be part of a broader intelligence-gathering initiative. Keeping contraband out of prisons is complicated, in part because staff members are sometimes involved in smuggling schemes, the paper reports. For example, reports on criminal cases at the CoreCivic-operated Trousdale Turner Correctional Center include charges of employees bringing in drugs or cellphones, and a 2024 federal lawsuit highlighted the use of drones to deliver drugs to the prison yard.