The TBA will be closed Friday, July 4, for Independence Day. The office will reopen Monday at 8 a.m. CDT. As always, our TBA.org website has plenty of continuing legal education options and other information available to you 24/7. Reach out to staff directly using contact information posted on our online staff directory.

July marks a new chapter for the TBA YLD as the bar year begins. For young lawyers, July is an ideal time to recharge, reset your focus and set meaningful goals for the months ahead.

Take a moment to envision where you want to be by the end of the year. What kind of work motivates you? What new challenges are you ready to take on? This is a great time to set clear and meaningful goals that reflect your values and interests. Focus on areas that will help you grow, such as gaining confidence in a new practice area, contributing to a pro bono initiative or becoming more active in your legal community. Select a few goals that feel both purposeful and achievable, and create a plan to move forward with steady progress.

As a young lawyer, success isn't just about hitting deadlines or racking up billable hours. It's about working with purpose, rolling with the punches when things change, and making choices that help you grow and stay fulfilled in the long run. Use this moment to check in with yourself both personally and professionally. How are you managing your energy and well-being? Taking time to reflect and make thoughtful adjustments now can help you stay balanced, focused and prepared for whatever comes next.

Even if July does not mark the start of your fiscal year, it is still the midpoint of the calendar year. Take this opportunity to recharge and refocus so you can finish the year strong!

Cheers to a successful bar year!

JOHN K. BUSH, Circuit Judge. Saint Francis Hospital and Saint Francis Hospital- Bartlett (Hospitals), based in Tennessee, brought claims purporting to rely on their state’s common law for quantum meruit and unjust enrichment against Cigna Health and Life Insurance Company, a Connecticut-based insurer. The Hospitals claim that Cigna, under its health insurance policies, routinely pays less than reasonable value when the Hospitals provide emergency care to Cigna members. The Hospitals have no contract with Cigna constraining the amount the Hospitals can charge Cigna’s members for emergency services. In other words, the Hospitals are, in insurance parlance, “out-of-network.” Nonetheless, the Hospitals argue they have a quasi-contractual relationship with Cigna requiring it to pay more for emergency care than what its health insurance contracts provide. They base their argument on federal and state law requiring both that hospitals treat all emergency patients who need their care and that insurers cover emergency care. Essentially, the Hospitals believe Cigna has a duty to pay the full value of their services regardless of whether Cigna contracted with its members to limit its liability.

President Donald Trump has nominated four people to the Tennessee Valley Authority (TVA) Board of Directors. They are Knoxville lawyer and Knoxville Sports Authority Board member Jeff Hagood; Memphian Mitch Graves, the CEO of West Cancer Center and a current member of Memphis Light Gas and Water’s (MLGW) Board of Commissioners; Nashville businessman Lee Beaman; and Randall Jones of Alabama. Three of the vacancies were the result of Trump's firing members earlier this year. The Commercial Appeal and Knox News have more on the nominees, which now must be confirmed by the U.S. Senate.

In this accelerated interlocutory appeal, Father seeks to appeal the denial of his motion to recuse the trial court judge. Because we can find no evidence in the record of any bias that would require recusal, we affirm the trial court’s denial of the motion.

This is an interlocutory appeal as of right filed pursuant to Tennessee Supreme Court Rule 10B by the defendant, Keith Dessinger, concerning his motion seeking recusal of the trial court judge. Having reviewed the petition for recusal appeal filed by Mr. Dessinger, we determine it to be fatally deficient. We therefore dismiss the appeal.

In this constitutional challenge involving a non-judicial foreclosure, the trial court determined that Tennessee Code Annotated § 35-5-106 is not unconstitutional as applied because the City of Chattanooga acted in a proprietary capacity when it conducted a non-judicial foreclosure of a deed of trust. Thus, only private conduct is at issue and constitutional rights are not implicated. We affirm.

Because the order from which the appellant has filed an appeal does not constitute a final appealable judgment, this Court lacks jurisdiction to consider this appeal.

The U.S. Senate narrowly passed President Donald Trump’s sweeping “One Big, Beautiful Bill Act” after intense negotiations and a 27-hour amendment marathon, with Vice President J.D. Vance casting the tie-breaking vote. Key to the bill’s passage was securing the support of Sen. Lisa Murkowski, R-Alaska, whose concerns about deep Medicaid and SNAP cuts were addressed through last-minute changes and a $50 billion rural hospital relief fund. The legislation extends Trump-era tax cuts, boosts military and border security funding, phases out renewable energy credits, and raises the debt ceiling by $5 trillion. In a near unanimous vote, senators removed the bill's provision limiting states' ability to enact laws regulating artificial intelligence according to the Associated Press. A group of Tennessee state lawmakers had urged the Senate to remove the provision, which could have impacted the state's ELVIS Act, The Tennesse Journal reports. Despite the Senate win, the bill faces serious hurdles as it goes back to the House, The Hill reports.

The U.S. District Court for the Middle District of Tennessee will appoint a new full-time magistrate judge upon the resignation of Magistrate Judge Alistair Newbern, effective Jan. 2, 2026. Application forms and more information on the position may be obtained from Chief Deputy Clerk Vicki Kinkade, 719 Church St., Ste. 1300, Nashville, TN 37203. The application form is also available as a download from the court’s website. Applications must be submitted by applicants personally and must be received by Aug. 15. More information and the requirements for candidates are laid out in the public notice of appointment.