NALBANDIAN, Circuit Judge. Terrell Anthony Hargrove appeals the denial of a writ of habeas corpus. He claims that prison officials unlawfully denied him access to First Step Act time credits. But Hargrove has already been placed on supervised release. And because we hold that First Step Act credits cannot be used to reduce a supervised-release term, we dismiss Hargrove’s appeal as moot.

KAREN NELSON MOORE, Circuit Judge. While working as a Certified Nursing Assistant Technician at Morristown-Hamblen Hospital Association (“MHHA”), Samantha Graf lodged a complaint of sexual harassment with a representative of the hospital’s human-resources department. According to Graf, during a lunch break and on hospital grounds, one of the hospital’s security guards, Thomas Ogle, had raped her. After conducting a limited investigation into the complaint, the HR representative determined that the sexual interaction between Graf and Ogle had been consensual. Shortly thereafter, MHHA terminated Graf on the grounds that she had violated hospital policy by having intercourse while on the clock and in an unauthorized area. Graf filed suit against MHHA alleging violations of Title VII and the Tennessee Human Rights Act (“THRA”) and bringing various state tort claims. Two of those claims—Graf’s retaliation claim and her claim of negligent infliction of emotional distress—survived summary judgment. Prior to trial, MHHA moved for the admission of a variety of evidence of Graf’s sexual history pursuant to Federal Rule of Evidence 412(a), including evidence of Graf’s relationship with Ogle. The district court denied in part and granted in part the motion, allowing MHHA to introduce evidence of Graf’s communications with Ogle prior to and following the alleged rape. The case proceeded to trial, and a jury returned a verdict in favor of MHHA on all counts. On appeal, Graf challenges the judgment against her, arguing that the district court erred as a matter of law in interpreting Title VII to require that she prove that she did not consent to the alleged rape. And she argues that the district court abused its discretion in admitting a variety of evidence of her sexual history and predisposition, in violation of Federal Rule of Evidence 412. But because the district court accurately interpreted the requirements of Graf’s Title VII retaliation claim, and because it did not abuse its discretion in allowing the admission of limited evidence of her sexual history, we AFFIRM.

LARSEN, Circuit Judge. Between 1994 and 2018, Mark Deakins sexually abused three boys. In 2022, he was indicted on five counts relating to that abuse. He was subsequently convicted via bench trial on all charges and sentenced to life plus ten years’ imprisonment. No. 24-5223 United States v. Deakins Page 2 He appeals both the conviction and his sentence, raising a variety of challenges. For the following reasons, we AFFIRM.

A Grundy County jury convicted the defendant, John W. Smith, of one count of first-degree murder, one count of attempted first-degree murder, one count of attempted second-degree murder, one count of aggravated assault, and eight counts of reckless endangerment, for which he received an effective sentence of life imprisonment plus twenty-two years. On appeal, the defendant contends the evidence presented at trial was insufficient to support his convictions. The defendant also argues the trial court erred in admitting the 911 calls, in refusing to admit Jerome Powell’s statement that “she had her gun then,” and in imposing an excessive sentence. Following our review, we affirm the defendant’s convictions. However, we reverse the imposition of consecutive sentences and remand to the trial court for a new sentencing hearing for consideration of the consecutive sentencing factors outlined in State v. Wilkerson, 905 S.W.2d 933 (Tenn. 1995). We also remand for corrected judgment forms in counts five, fourteen, and fifteen.

The Sevier County Bar Association is sponsoring the 11th Annual Sevier County Juvenile Seminar on Oct. 14, with all proceeds benefiting the Women’s Recovery Home. The virtual program will cover juvenile law topics applicable statewide. Register for the program and view the agenda. For those who register, the training will remain available through Nov. 30.

The U.S. Supreme Court will hear a case challenging President Donald Trump’s tariffs policy in November under an accelerated timetable. The tariffs will stay in place in the meantime, the Associated Press reports. The court agreed to take up an appeal from the Trump administration after lower courts found most of his tariffs illegal. Small businesses and states that challenged the tariffs say they have nearly driven their businesses to bankruptcy. “Congress, not the President alone, has the power to impose tariffs,” attorney Jeffrey Schwab with the Liberty Justice Center said. The Trump administration argues the 1977 International Emergency Economic Powers Act grants the president broad authority to regulate imports, warning that striking down the tariffs could harm the economy and weaken U.S. leverage in trade negotiations.

Attorneys for Byron Black, the man executed by the state of Tennessee last month, say an autopsy confirmed that he suffered from pulmonary edema before his death. But they also say other questions about what he experienced during his execution remain unanswered. “The autopsy report itself fails to document the condition of the veins, which leaves unanswered questions. It also fails to document the EKG results. TDOC [Tennessee Department of Corrections] has indicated that it will not even begin to answer our public records request until Dec. 3 ... As we move through discovery in chancery court, we will obtain further information as to what went wrong," Black's lawyers said according to the Nashville Banner newsletter. Media witnesses, including the Banner, reported that Black lifted his head, groaned and said “oh, it’s hurting so bad” during his Aug. 5 lethal injection.

The TBA’s 2025 Creditors Practice Annual Forum will take place Oct. 1 at the Tennessee Bankers Association’s Bradley L. Barrett Training Center in Nashville. The program offers three general and one dual CLE credit with sessions covering case law and rule updates, e-filing, artificial intelligence and the sovereign citizen movement. Registration begins at 9 a.m. with programming scheduled from 10 a.m. to 3:15 p.m. CDT, followed by a networking reception. For more information and to register, visit the TBA website.

Tennessee Attorney General Jonathan Skrmetti announced his office has filed a lawsuit against the former owners of Dynamic Therapy Center, a now-defunct Mt. Juliet clinic, accusing them of defrauding TennCare, the state’s Medicaid program. The lawsuit, filed in Wilson County Circuit Court, alleges the defendants knowingly submitted false claims between 2020 and 2023 by billing TennCare for individual physical, occupational and speech therapy sessions while providing group therapy to children in “camps.” Because TennCare reimburses individual therapy sessions at higher rates than group sessions, the scheme allegedly resulted in more than $300,000 in overpayments, according to a press release. The state is seeking recovery of the funds, treble damages, civil penalties of $14,308 to $28,619 per violation, and other remedies allowed under the Tennessee Medicaid False Claims Act.

Crime in Memphis continued to fall through the first eight months of 2025, according to new data from the Memphis Police Department. The Daily Memphian reported this week that there were 28,660 overall incidents from January through August, a 23% decrease from 2024 and a 37% decrease from 2023. MPD’s data represent the number of reported incidents, which may involve more than one victim. The department reported declines across all major categories, with the largest drops in property crimes. Larceny, burglary and robbery are all at 25-year lows. In July, MPD reported overall crime was down 20% compared to the same point in 2024. The news comes amid reports from The Daily Memphian that the White House, Tennessee Gov. Bill Lee’s office and Memphis Mayor Paul Young’s administration have discussed a possible deployment of National Guard troops to Memphis.