Are you interested in serving with the TBA in 2026? Several positions will be voted on this spring. Available opportunities include a new vice president from the Eastern Grand Division, three district governors and six grand division governors (two from each division) on the TBA Board of Governors, and four positions representing Tennessee in the American Bar Association (ABA) House of Delegates. Learn more about these positions in the 2026 Election Notice published in the November/December 2025 issue of the Tennessee Bar Journal or download a nominating petition. Nominating petitions should be submitted no later than Jan. 15, 2026 to barED@tnbar.org. Questions? Visit the TBA’s election webpage for more information.

Douglas Malcolm Carey, a 2023 graduate of the University of Memphis Cecil C. Humphreys School of Law, died Nov. 27 at his home in Crozet, Virginia. He had been working as a civil litigator for The Crone Law Firm in Memphis. Carey grew up in Virginia and New York. He attended the Waldorf School of Saratoga Springs where he focused on track, theater, the circus arts and martial arts. He attended SUNY Oswego and graduated with a dual major of philosophy and biochemistry in 2016. Outside of work, he was a certified personal trainer and was passionate about power lifting and running. A memorial service is being planned at the University of Virginia Chapel in Charlottesville, Virginia. In lieu of flowers, the family asks that donations be made to the TSC Alliance of Silver Spring, Maryland.

The TBA is offering an on-demand virtual 10-hour package as part of its Year End CLE event. The bundle includes a mix of sessions focused on ethics, AI, law practice management, professional skills, wellness and a legislative update. Check out the specific courses included in the package on the TBA website. Looking for something else? TBA also has six, eight, 12 and 15-hour packages, packages based on specific topics or practice areas, live webcasts, and on-demand videos all month long. Explore all the options to complete your CLE requirement by Dec. 31.

Family law arbitration promises efficiency, privacy and flexibility — but does the Revised Uniform Arbitration Act (RUAA) truly safeguard the unique needs of divorcing spouses, parents and children? The TBA Family Law and Dispute Resolution sections will host a joint program on Dec. 18 at 11 a.m. CST that examines whether the RUAA provides adequate protections for family law litigants or whether specialized legislation is required. Participants will explore statutory gaps, including confidentiality, child‑focused standards, judicial review and enforceability of awards. Comparative insights from jurisdictions with domestic relations arbitration statutes will highlight best practices and potential reforms. Reserve your spot today!

Join speakers from The Legal Burnout Solution on Dec. 9 for a one-hour webcast on developing mindful law practice management skills designed to strengthen your focus, organization and long-term success while protecting against burnout. The session will focus on using mindfulness to develop resilience, cultivate sustainable work habits, enhance focus and efficiency, and improve client and team communication and collaboration — all with an eye to protecting yourself against ethical missteps. Learn more or register on the TBA website.

Join your colleagues in Nashville on Jan. 23, 2026, for a full day of in-person construction law education tailored to both new and experienced practitioners, featuring introductory morning sessions that build foundational knowledge and advanced afternoon sessions delving into complex issues. The morning program provides a practical overview of essential topics, including preserving and enforcing lien rights, reviewing recent case law developments, and avoiding common construction law mistakes. After lunch, the focus shifts to more advanced matters, beginning with payment obligations and statutory compliance under the Prompt Pay Act, followed by an exploration of the growing role of artificial intelligence in construction projects and legal practice, and concluding with ethics considerations unique to construction law to support strong professional judgment and compliance. Reserve your spot today!

The Governor’s Council for Judicial Appointments will consider five applicants when it meets to select nominees for an upcoming vacancy on the Court of Appeals Eastern Section resulting from the retirement of Judge D. Michael Swiney on Jan. 12, 2026. The applicants are Jeffery Scott Griswold, Christopher Dunn Heagerty, Rachel Park Hurt, William Erwin Phillips II and Melissa Thomas Willis. Public interviews are scheduled for Jan. 7, 2026, at 10 a.m. EST in the courtroom of the Knoxville Supreme Court Building at 505 W. Main St., Knoxville, TN 37902. After the interviews, the council will vote to send up to three applicants to the governor. For questions, contact Council Administrative Office of the Courts (AOC) Assistant General Counsel Laura Blount at 615-741-2687.  

COLE, Circuit Judge. After the bankruptcy court denied plaintiffs’ motion for summary judgment and granted partial summary judgment to Max Salas, plaintiffs obtained leave to pursue an interlocutory appeal in the district court. The district court affirmed and remanded the matter to the bankruptcy court for further proceedings. It did not certify the issue for appeal or the order as final. For their part, plaintiffs did not seek certification to this court. Because we lack jurisdiction, we must dismiss the appeal.

HERMANDORFER, Circuit Judge. Elizabeth Cristales-de Linares, a native and citizen of El Salvador, was denied a U.S. visitor visa. Two months later, she entered the United States illegally along with her two daughters. At a later removal hearing, Cristales-de Linares sought asylum, withholding of removal, and protection under the Convention Against Torture. She asserted fears that, if removed to El Salvador, men potentially associated with an unknown gang would target her because she is a Salvadoran woman and a business owner. The immigration judge denied her application. The Board of Immigration Appeals affirmed. Because Cristales-de Linares failed to establish that she qualifies for the relief she seeks, we deny the petition.

RITZ, Circuit Judge. After an immigration judge denied petitioners’ application for asylum, withholding of removal, and protection under the Convention Against Torture (“CAT”), they appealed to the Board of Immigration Appeals (“BIA”). The petitioners timely submitted a brief in support of their appeal, but the BIA rejected the brief because it listed an address for their attorney that was different from the address provided on the attorney’s notice of appearance. So petitioners re-submitted their brief and moved the BIA to accept the now-late filing, but the BIA denied that request. The BIA then summarily denied petitioners’ appeal, on the basis that they did not file a supporting brief when they indicated they would. Petitioners petition for review of the BIA’s rejection of their brief and denial of their appeal. Because the BIA abused its discretion, we grant the petition for review.