Tennessee Attorney General (AG) Jonathan Skrmetti has announced Phase 2 of Operation Robocall Roundup, expanding a crackdown on illegal robocalls to include four of the largest telecommunications companies in the country. According to Skrmetti, Inteliquent, Bandwidth, Lumen and Peerless have collectively facilitated an estimated 3.4 billion scam calls nationwide since 2020. “Despite action by attorneys general across the country, [these companies] continue to profit from routing these illegal calls into millions of American homes," he said. "We are intensifying enforcement against these bad actors to ensure stronger safeguards for consumers.” Read more in a press release from the AG's office.

It's time for TBA's Year End CLE event! This annual tradition brings you quick and easy content, right from the comfort of your own home or office, whether you need one hour of CLE or 15. There is a quality mix of packages based on hours needed or topic, live webcasts and on-demand video — all offered virtually. And our excellent customer support at cle@tnbar.org will get you over the finish line for your 2025 CLE requirements. Select packages by hour (six, eight, 10, 12 or 15) or by topic, or build your own any time by visiting cle.tba.org to access over 200 on-demand programs. Topical packages include AI Essentials, Attorney Wellness, Ethics, Experience TBA Convention, General Solo & Small Practice, Law Practice Management, Mediation Ethics & CME and the Rookie Series. All offer dual hours, making it easy to check that off your December to-do list. Packages also are available based on practice area. Check out all the options here!

Nashville attorney Patricia Lee Newton died Nov. 30 at age 77. She graduated from the University of Tennessee (now Winston) College of Law in 1975 and practiced law at Gilreath & Associates in Knoxville. Newton moved to Nashville in 1978, where she became an assistant public defender for Metro Nashville government. In 1981, Newton began her 45-year career with the Tennessee state government, during which she held numerous leadership roles. Visitation will take place on Dec. 13 from noon to 2 p.m. CST, immediately followed by a funeral mass at St. Mary of the Seven Sorrows Church, 328 Rep. John Lewis Way N, Nashville 37219. In lieu of flowers, the family requests donations to Old Friends Senior Dog Sanctuary, 765 Nonaville Road., Mt. Juliet, TN 37122.

Mark your calendars for the 2026 Estate Planning & Probate Forum, scheduled for March 6, 2026, in Franklin. This annual event will provide seven hours of CLE credit and include sessions on litigation and estate planning, public receivership, a probate panel, and a legislative update. Speakers will include Rob Malin, Rebecca Blair, Chancellor William Cole, Jennifer Exum, Lisa Helton, Robin Miller, David Parsons, Al Secor, Andrea Sinclair, Jared Smith and Ashley Stearns. Get more information and register on the TBA's website. Section members receive discounted registration. Not a section member yet? Get started here.

The TBA is offering a three-hour "AI Essentials" CLE package focused on Artificial Intelligence (AI) and the practice of law, designed to help Tennessee lawyers quickly complete their remaining hours for 2025. Check out the specific courses included in the package on the TBA website. Looking for something else? TBA also has six, eight, 10, 12 and 15-hour packages, packages based on specific topics or practice areas, live webcasts and on-demand video all month long. Explore all the Year End options to complete your CLE requirement by Dec. 31.

TBA's new "Sunrise Series" of early morning CLE offerings continues next week with "10 Ethical Tips from Hollywood Movies." Grab a cup of coffee and enjoy this one-hour webcast reviewing the Model Rules of Professional Responsibility as those rules are depicted in popular movies. Join Joel Oster, the Comedian of Law, as he analyzes the difference between professionalism and ethics and encourages attorneys to view their career as a professional calling. For more information and to register, visit the TBA's website.

The TBA will hold its second annual Conference on Artificial Intelligence and the Law (TCAIL2) on Dec. 12 in Nashville, offering a full day of programming focused on the rapidly evolving intersection of AI and legal practice. The conference will run from 8:45 a.m. to 4:15 p.m. CST and provide up to six dual hours of CLE credit. Sessions will feature live demonstrations of leading AI tools, guidance on navigating ethical and regulatory risks, and strategies for handling AI-generated evidence in court. Speakers include A.J. Bahou, Maura Grossman, Richard Littlehale, Lucian Pera, Neal Pinkston, Bill Ramsey and Oliver Roberts. For more information and to register visit the TBA website.

DAVIS, Circuit Judge. Gustavo Adolfo Osabas-Rivera petitions for review of the Board of Immigration Appeals’ final order affirming an immigration judge’s decision finding him ineligible for asylum due to an untimely application and denying on the merits his applications for withholding of removal and protection under Article III of the Convention Against Torture. First, we lack jurisdiction to review the Board’s determination that Osabas-Rivera failed to establish extraordinary circumstances warranting waiver of the deadline for his untimely asylum application. And second, we hold that Osabas-Rivera abandoned a dispositive issue as to his withholding-of-removal claim—specifically, whether the Honduran government is unable or unwilling to protect him from gang violence. He does not raise his Convention Against Torture claim before us. Therefore, we DENY the petition for review in part and DISMISS in part.

KETHLEDGE, Circuit Judge. Stacy Owens pled guilty to criminal contempt, and the district court sentenced her to 11 months in prison. She now challenges the procedural and substantive reasonableness of her sentence. We reject her arguments and affirm.

A Gibson County jury convicted the Defendant, Joshua Damone Pewitte, of three counts of rape of a child. The trial court imposed an effective sentence of eighty years’ imprisonment. On appeal, the Defendant broadly challenges whether the election process was sufficient to protect against the risk of a non-unanimous verdict. Specifically, the Defendant raises three inter-related issues regarding the election process on plain error review: (1) the State made its initial election outside the presence of the jury and did not mention its election to the jury until its rebuttal closing argument; (2) the State referenced examples of uncharged conduct during its closing argument; and (3) the language from the trial court’s unanimity instruction was different from the State’s election and closing argument. Upon our review, we respectfully affirm the judgments of the trial court.