The TBA YLD Rookie Series continues with a webcast on the role of federal magistrate judges on Dec. 3 at 12 p.m. CST. Make plans now to join U.S. Magistrate Judges Mike Dumitru, Debra Poplin and Cynthia Wyrick for a panel moderated by TBA YLD Board member and CLE Chair for East Tennessee Weslen Lakins. Watch for more information coming soon.

The TBA Young Lawyers Division (YLD) will host “The Rookie Series: Compassionate Lawyering” webcast on Aug. 27 from noon to 1 p.m. CDT. The program will introduce attorneys to the principles of trauma-informed legal practice and explore how lawyers can better serve clients — especially those from marginalized or vulnerable backgrounds — by incorporating empathy and awareness into their work. Mental health professionals will join the discussion to examine how legal systems can unintentionally retraumatize clients and offer strategies for compassionate advocacy across various practice areas. For more information and to register, visit the TBA website.

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COLE, Circuit Judge. Each year on his birthday, William Plott received a payment from Wilcac Life Insurance Company under Wilcac’s annuity contract with the Department of Health and Human Services (HHS). After Plott died two months before his twenty-ninth birthday, his estate sought one final payment from Wilcac. Wilcac refused, and Plott’s estate sued Wilcac and HHS. The district court concluded that HHS was a necessary and indispensable party under Federal Rule of Civil Procedure 19, but as HHS could not be joined without defeating the district court’s subject matter jurisdiction, the district court dismissed the case. Because the district court improperly applied Rule 19, we reverse and remand for further proceedings.

NALBANDIAN, Circuit Judge. Two suspicious packages, two weeks apart, passed through the Cleveland Postal Service distribution center in early 2021. United States postal inspectors flagged both for a possible connection to drug trafficking. After more research that added to their suspicion, inspectors called for a canine sniff of the packages. The dog, Ciga, alerted to both. Based on this evidence, a Postal Inspector applied for search warrants to open the packages and both revealed evidence of illicit activity. The investigation that followed led to the arrest and indictment of Jaavaid McCarley- Connin for his role in a drug-trafficking conspiracy. He moved to suppress the evidence from the package searches. He claimed he was entitled to an evidentiary hearing and extrinsic evidence to undermine Ciga’s reliability. The district court denied the motions, so McCarley- Connin pleaded guilty but reserved his right to challenge the trial court’s ruling on the suppression motion. Now, he presses on us the same theory that the district court denied below. First, he claims that Florida v. Harris, 568 U.S. 237 (2013) entitles him to an evidentiary hearing because he offered extrinsic evidence undermining Ciga’s reliability. And second, he claims that even without a hearing, Harris required the court to consider his extrinsic evidence; if he had, the court would have found the affidavit lacked probable cause. Because Harris does not reach as far as McCarley-Connin suggests, we AFFIRM the district court.

A Davidson County jury found the Defendant, Baeho Shin, guilty of especially aggravated kidnapping, aggravated sexual battery, and domestic assault, among other offenses. Thereafter, the trial court imposed an effective sentence of twenty-two years’ incarceration. On appeal, the Defendant contends that the trial court violated his constitutional right to confrontation. More specifically, he argues that the court prohibited him from cross- examining the victim about her potential interest in obtaining a U visa, which is a non- immigrant visa available to certain victims of crime. Although the trial court later allowed the Defendant to recall the victim and question her on the topic, he argues that the delayed timing of the examination rendered the remedy inadequate and prejudicial. Upon our review, we conclude that the trial court acted within its discretion in controlling the scope and timing of the cross-examination and that any possible error was harmless beyond a reasonable doubt. We respectfully affirm the judgments of the trial court.

Antwon William Santos, Defendant, claims that the trial court erred in finding that he violated the terms of his probation and in ordering him to serve the balance of the sentence in confinement. After a thorough review of the record and applicable law, we affirm the judgment of the trial court.

The Defendant, Justin Rivers, was convicted of aggravated child neglect and received a sentence of fifteen years in confinement. On appeal, the Defendant argues: (1) his motion for judgment of acquittal should be treated as a prematurely filed motion for new trial; (2) the evidence is insufficient to support his conviction; and (3) the aggravated child neglect statute is unconstitutionally vague. After review, we dismiss the appeal due to its untimeliness.

Pursuant to a plea agreement, Defendant, Demarcus Montay Montgomery, entered guilty pleas for aggravated assault against a first responder and evading arrest involving the risk of death or injury in exchange for a three-year sentence, with the trial court to determine the manner of service. Following a sentencing hearing, the trial court imposed a sentence of three years’ confinement. On appeal, Defendant argues that the trial court abused its discretion by sentencing him to full confinement rather than probation. Upon review, we affirm the judgments of the trial court.

Petitioner, King Allah James, appeals the post-conviction court’s summary denial of his petition for post-conviction relief in which he challenged his guilty pleaded convictions for assault, vandalism, and two counts of aggravated assault and his effective six-year sentence. On appeal, Petitioner contends that the post-conviction court erred in finding that he failed to establish a colorable claim for relief. Upon review, we affirm the judgment of the post-conviction court.