LARSEN, Circuit Judge. A jury convicted Kelli Prather of bank fraud, wire fraud, aggravated identity theft, and making a false statement on a loan application. The district court sentenced her to 84 months’ imprisonment. Prather appeals her conviction and sentence. For the following reasons, we AFFIRM.

The Defendant, Jonnella Risharra Hambrick, was convicted by a Davidson County Criminal Court jury of attempted second degree murder, employing a firearm during the commission of a dangerous felony, and two counts of aggravated assault and received an effective twenty-year sentence. On appeal, the Defendant contends that the trial court erred by denying her the right to counsel at the trial and by imposing a sentence without her being present. Because we agree that the Defendant was denied her right to counsel and that she had a constitutional right to be present for sentencing, we reverse the judgments of the trial court and remand for a new trial.

The Defendant, Michael Flamini, Jr., was convicted by a Knox County Criminal Court jury of possession with the intent to manufacture, deliver, or sell one-half gram or more of methamphetamine, a Class B felony; and possession with the intent to manufacture, deliver, or sell less than fifteen grams of fentanyl, a Class C felony. See T.C.A. §§ 39- 17-434 (2018) (possession with intent to manufacture, deliver, or sell methamphetamine); 39-17-417 (Supp. 2020) (subsequently amended) (possession with the intent to manufacture, deliver, or sell fentanyl). The trial court sentenced the Defendant as a Range II offender and imposed concurrent sentences of fifteen years and ten years, respectively. On appeal, the Defendant contends that the trial court (1) erred by denying his motion to suppress, (2) erred by denying his motion for a mistrial, and (3) violated his right to remain silent by admitting evidence related to a civil asset forfeiture proceeding. We conclude that the trial court erred by admitting evidence of an asset forfeiture order. However, we, likewise, conclude that the error was harmless and affirm the judgments of the trial court.

One day after the Department of Justice (DOJ) closed its investigation into the Memphis Police Department (MPD) and possible civil rights violations, Stand for Children Tennessee and the American Civil Liberties Union (ACLU) submitted public records requests for "response to resistance" forms and internal investigation documents created since the DOJ report was released. The groups also are asking for policies that were in effect prior to Tyre Nichols being beaten by police in 2023. Community advocates say that a task force formed in lieu of federal oversight lacks transparency, and that collected data could inform legal action and continued advocacy for police reform. The Commercial Appeal reports that the effort is part of a broader campaign across seven states where DOJ findings were made but no consent decrees were signed.

For the week of May 19, 2025 - May 23, 2025

Past TBA President and University of Tennessee College of Law (now Winston College of Law) graduate Jim Emison has devoted much of his retirement to finding justice for Elbert Williams, the first known NAACP member to be racially terrorized and slain. In 1939, Williams helped found the Brownsville chapter of the NAACP, which sought to regain voting rights for Haywood County African Americans. The next year, police and one civilian forcibly removed Williams from his home. Williams’ body was pulled out of the Hatchie River three days later with two bullet holes in his chest. Emison says, “Pursuing justice for Williams’ murder has taught me so much. I’m grateful to Vanderbilt because what perhaps is even better than good grades is a yearning to keep learning. My professors certainly instilled that in me.” Read more about Emison's work in this profile in Vanderbilt Magazine. Emison received his undergraduate degree from Vanderbilt.

Republican U.S. Rep. Andy Ogles, who represents Tennessee’s 5th Congressional District, held a press conference on Memorial Day to announce that two congressional committees will investigate Nashville Mayor Freddie O’Connell’s response to recent immigration raids in the city. “The Homeland Security and the Judiciary committees will be conducting an investigation into the mayor of Nashville, his conduct and whether or not federal dollars have been used in criminal enterprise,” Ogles said. The Nashville Banner reports that while taking questions from the media, Ogles stated that he believed only citizens are entitled to due process and dismissed a question about raids causing fear in Nashville’s Latino community. About 100 protesters disrupted the event, which was held in the otherwise closed state capitol building, by banging on windows, blowing an air horn and chanting opposition to Ogles and U.S. Immigration and Customs Enforcement (ICE).

U.S. District Judge John Bates in Washington, D.C., on Friday permanently blocked President Donald Trump’s executive order targeting law firm Jenner & Block, ruling it an unconstitutional abuse of the president’s power, according to Bloomberg News. The firm sued the administration on March 28 in response to a March 25 executive order that sanctioned the firm for its pro bono work and ties to Special Counsel Robert Mueller and his investigation into Russian interference into the 2016 election. Bates initially imposed a temporary halt on the order. In Friday's ruling, he said, “This order, like the others, seeks to chill legal representation the administration doesn’t like, thereby insulating the Executive Branch from the judicial check fundamental to the separation of powers.” In a second case,  U.S. District Judge Richard Leon today ruled in favor of WilmerHale’s request to strike down a similar executive order targeting it from March 27. Leon also found that order unconstitutional and granted summary judgement to the firm in lieu of proceeding to a full trial.

Knox County Criminal Court Judge Steve Sword on May 21 dismissed the attempted murder convictions against Ahmad Gatlin, who had been sentenced to 31 years in prison when he was a teenager. Now 20, Gatlin will be granted a new trial due to recently discovered cell phone data that corroborates his claim that he was across town when the crime was committed. Knox News reports that Gatlin was convicted in 2023 after police and prosecutors argued he was in a car when shots were fired into another car near Austin-East Magnet High School in 2021. Knoxville defense attorney Stephen Ross Johnson helped Gatlin's defense team with the challenge and says he is now formally joining the team to represent Gatlin pro bono should the state seek a new trial. According to WBIR, law students from the Wrongful Convictions Clinic at the University of Tennessee Winston College of Law also joined the defense team. Director of Clinical Programs and Associate Professor of Law Joy Radice said, “Lawyers representing the poor whose life or liberty are at stake in a criminal case are overworked, chronically underfunded, and often unable to research and obtain critical and effective expert assistance to meet the awesome power of the state or federal government. I am honored that the [clinic] could be a part of helping to fill that gap in Ahmad’s case, as [it] has for over 75 years for so many others."

The reporting staff of the Nashville Banner will receive the Tennessee Bar Association’s 2025 Fourth Estate Award for its reporting last year on the Nashville criminal court system. The award will be presented at the 2025 Lawyers Luncheon set for June 13 as part of the TBA’s Annual Convention in Franklin. Throughout 2024, the Nashville Banner published a series of stories designed to bring transparency and accountability to the Davidson County Criminal Court. Among the issues covered was the court’s decision to remove computers that previously had provided public access to court records, and subsequent changes in the process of how to access those records. In announcing the award, TBA President Ed Lanquist Jr. said, “Nashville Banner news staff demonstrated tenacious and courageous reporting last year as they worked to bring visibility to issues impacting the operations of the Nashville criminal court system. We thank them and honor them for that important contribution.” Read more in the TBA’s press release.