Husband and Wife divorced. In dividing the marital estate, the trial court determined that an account inherited by Wife had been transmuted into marital property and that Wife had dissipated a substantial portion of the transmuted account. Considered as a whole, the trial court allocated the marital estate in a manner that Wife asserted was inequitable. She repeatedly requested findings by the trial court explicating its division of marital estate. The trial court declined to provide such findings. On appeal, Wife challenges the trial court’s classification of the aforementioned account and its conclusion that she dissipated the account. Wife also challenges the trial court’s overall division of marital property both as being inequitable and for the insufficiency of the trial court’s findings. We affirm the trial court’s ruling as to transmutation. We vacate the trial court’s ruling as to dissipation and the trial court’s division of property, and we remand for further proceedings.

The plaintiff, Patricia Slate, appeals the dismissal of her complaint for failing to state a claim upon which relief can be granted against either of the defendants. Because the appellant’s brief is profoundly noncompliant with Rule 27 of the Tennessee Rules of Appellate Procedure, we dismiss this appeal.

In this post-divorce dispute, a father petitioned to modify the permanent parenting plan and child support. The mother counterpetitioned for civil contempt alleging the father had willfully violated the parenting plan. After a bench trial, the court denied the father’s petition and held him in civil contempt. Because the evidence preponderates in favor of a finding of a material change in circumstance sufficient to modify the residential parenting schedule, we vacate the denial of the father’s petition to modify the parenting plan and remand for the court to determine whether modification is in the child’s best interest. We reverse the court’s decision to hold the father in civil contempt for failure to maintain insurance coverage because the decision lacked sufficient factual support. Given our disposition of these issues, we also vacate the court’s award of attorney’s fees to the mother as the prevailing party. Otherwise, we affirm.

This case addresses whether the Uniform Arbitration Act confers subject matter jurisdiction on Tennessee courts to confirm an arbitration award when the parties’ arbitration agreement specified that arbitration would occur in another state. Berkeley Research Group, LLC and Southern Advanced Materials, LLC entered into a contract which provided that any dispute would be resolved by arbitration in Pennsylvania, not Tennessee. A dispute arose and the parties entered arbitration, which resulted in an award to Berkeley. Berkeley sought to confirm the arbitration award in Shelby County Chancery Court. The trial court confirmed Berkeley’s arbitration award and entered judgment. The Court of Appeals reversed, finding that while the trial court had subject matter jurisdiction, it lacked personal jurisdiction over Southern. We find that Tennessee courts lack subject matter jurisdiction to confirm an arbitration reward when the parties agreed arbitration would occur in another state. As a result, the trial court lacked jurisdiction to confirm an award resulting from an arbitration the parties agreed would occur in Pennsylvania. We vacate the judgments of the lower courts and dismiss the petition to confirm the award.

Just six weeks after the special election to fill a Middle Tennessee congressional district vacated by Mark Green, candidates already have begun picking up petitions to run when the term expires in November. State Rep. Vincent Dixie, D-Nashville, who ran in the Democratic primary for the special election, is the latest candidate to pick up a petition. He joins Democrat Joshua Warren Sales and independent Teresa Christie. Rep. Aftyn Behn, D-Nashville, who was the Democratic nominee in the special election has announced she would not run again. Rep. Matt Van Epps, who won the special election, has filed his signed petition to seek re-election. The Nashville Banner reports on the race.

A bill introduced last week would allow state prison staff to disable illegal drones that smuggle cell phones, drugs and other prohibited items into state prisons. Republican Sen. Tom Hatcher, a retired 10-year veteran sheriff’s deputy from Blount County, introduced SB1631, which also would make it a crime to fly an unmanned aircraft over a prison facility. Violators could face three to 15 years in prison and fines of up to $10,000, according to The Tennessean. The bill would cover state prisons, county jails and mental health institutions. Correction officials are seeking funding for department-operated drones to patrol prison perimeters, deter unauthorized drone flights and strengthen overall surveillance.

The next free advice clinic for Black-owned small businesses and nonprofits is set for noon to 1 p.m. CST on Feb. 19 in Nashville. The clinic, sponsored by the Arts & Business Council's Volunteer Lawyers & Professionals for the Arts and Bradley, provides assistance with business formation and corporate governance, review of contracts, and guidance in navigating local ordinances and state regulations. Space is limited so early registration is recommended. Attorneys should email vlpa@abcnashville.org to volunteer.

The U.S. Supreme Court ruled unanimously that a federal victim restitution law constitutes criminal punishment, reviving a challenge from a convicted bank robber to a statute enacted after his crime. In a 9-0 decision, the court sided with Holsey Ellingburg Jr., who is contesting the government’s efforts to collect restitution related to a 1995 bank robbery under the 1996 Mandatory Victims Restitution Act, Bloomberg Law reports. Writing for the court, Justice Brett Kavanaugh said the law “is plainly criminal punishment for the purposes of the Ex Post Facto Clause,” which prohibits the government from imposing criminal penalties based on laws that were not in effect at the time of the offense. The ruling reversed a lower court decision that had rejected Ellingburg’s challenge on the grounds that the restitution statute was not criminal punishment. Justice Clarence Thomas filed a concurring opinion joined by Justice Neil Gorsuch.

The Tennessee Supreme Court temporarily suspended Sullivan County lawyer Ricky A. W. Curtis from the practice of law on Jan. 22. The court took the action after determining that Curtis failed to respond to the Board of Professional Responsibility concerning one complaint of misconduct. He is immediately precluded from accepting any new cases and must cease representing existing clients by Feb. 21. The suspension will remain in effect until dissolution or modification by the court.

The Tennessee Supreme Court temporarily suspended Rutherford County lawyer Dalen L. P. Farmer from the practice of law on Jan. 22. The court took the action after determining that Farmer failed to respond to the Board of Professional Responsibility concerning one complaint of misconduct. He is immediately precluded from accepting any new cases and must cease representing existing clients by Feb. 21. The suspension will remain in effect until dissolution or modification by the court.