Of Tennessee’s 95 counties, 79 reported unemployment rates below 5% in February, even as most counties saw increases from the previous month, according to data from the Tennessee Department of Labor and Workforce Development. Unemployment rates rose in 87 counties compared with January, remained unchanged in five and decreased in three. Williamson, Macon and Cheatham counties recorded the state’s lowest unemployment rates at 3%, while Pickett County had the highest rate at 6.7%, followed by Perry County at 6.6% and Cocke County at 6.5%. Tennessee’s seasonally adjusted unemployment rate was 3.6% in February, up slightly from January but still below the national rate of 4.4%.

Reporters from across the state gathered in Nashville today to learn about open meetings law, investigative journalism and more during the sixth annual Reporters Workshop program, produced jointly by the Tennessee Bar Association, the Tennessee Association of Broadcasters and the Tennessee Press Association Foundation. Participants were selected from applicants interested in developing a deeper understanding of media law issues that may affect their everyday work.

Today's programming included a panel of veteran investigative reporters — Phil Williams from NewsChannel 5, Meribah Knight from WPLN News and Stephen Elliott from the Nashville Banner — moderated by Amy Mohan of Sherrard Roe Voigt & Harbison. Other speakers were Jennifer Safstrom with Vanderbilt's First Amendment Clinic, who presented on reporter's privilege; a panel moderated by Todd Hambidge from Holland & Knight on public records that included Lisa Davidson and Ashley Rinehart from the Metro Nashville Police Department and Jay Miller from the Administrative Office of the Courts; and Deborah Fisher from Tennessee Coalition for Open Government, who discussed the open records law.

Programming will continue on Saturday with a session featuring an overview of defamation with Safstrom and Ryan Riedmueller from the Vanderbilt First Amendment Clinic and a panel on covering state and local government with Alex Apple from Nashville Mayor Freddie O’Connell's Office, Steve Cavendish from the Nashville Banner, Holly McCall from the Tennessee Lookout, and Erik Schelzig with State Affairs (Tennessee Journal). That panel will be moderated by Clint Brewer from Imperium Public Strategies. The day will wrap up with a panel moderated by Robb Harvey of Holland & Knight on covering the courts with Judges Valerie Smith and Ana Escobar and Chancellor Anne Martin. See photos from the event. Thanks to this year's sponsors Holland & Knight, Sherrard Roe Voigt & Harbison and Womble Bond Dickinson.

Nashville attorney Malcolm Leonard McCune died April 16 at age 78 after a long illness. He earned his law degree from Vanderbilt University Law School, graduating in 1973 as an associate editor of the Vanderbilt Law Review and a member of the Order of the Coif. He later earned a masters of business administration from Belmont University. McCune focused his career on complex products liability litigation, practicing with the firms of Maddin, Miller & McCune; Blackburn & McCune; and most recently, McCune, Zenner and Happell. McCune was a member of the American College of Trial Lawyers and the American Board of Trial Advocates, served as vice president of the Tennessee Defense Lawyers Association, and was a member of the Defense Research Institute. He also coached high school mock court teams. Services will be held May 2 at Woodlawn Funeral Home, 660 Thompson Lane, Nashville, TN 37204.

The Defendant, Corey Ellis, appeals from the order of the trial court revoking his probation. The Defendant contends the trial court failed to consider the Defendant’s amenability to future rehabilitation or whether he was a danger to others when deciding on revocation. He also argues that the trial court failed to consider an updated risk and needs assessment. After review, we affirm the judgments of the trial court.

HELENE N. WHITE, Circuit Judge. Plaintiff Cory Driscoll brought constitutional and state tort claims against Defendant Deputy Sheriff Jennifer Smiley after she shot him. Deputy Smiley appeals the denial of her motion for summary judgment based on qualified immunity and state statutory immunity. We AFFIRM.

KAREN NELSON MOORE, Circuit Judge. Alexander Ross and his then-wife bought a used car in Oklahoma. After he and his wife divorced, Ross moved to Michigan. Following his move, the former couple failed to make their car payments and their creditor hired Robinson, Hoover & Fudge, PLLC (“RHF”), an Oklahoma-based law firm, to bring a breach-of-contract action against Ross and his ex-wife in Oklahoma. Ross eventually defaulted. By that time, RHF had learned that Ross was living and working in Michigan. RHF then used the Oklahoma default judgment to submit a garnishment summons to the Oklahoma registered agent of Ross’s employer’s parent company. The parent company passed the garnishment summons to Ross’s employer, which began garnishing wages Ross earned in Michigan. Ross then filed this action in the U.S. District Court for the Eastern District of Michigan, bringing claims under the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692 et seq., and the Michigan Regulation of Collection Practices Act (“MRCPA”), Mich. Comp. Laws § 445.251 et seq. The district court dismissed the complaint after finding that RHF had not purposefully established minimum contacts with Michigan. Because RHF purposefully directed its actions at Ross, intentionally targeting him in Michigan and causing him to suffer his injury in the forum state, we REVERSE the judgment of the district court and REMAND for further proceedings consistent with this opinion.

JULIA SMITH GIBBONS, Circuit Judge. Plaintiff-Appellant Dean Koch appeals the dismissal of his complaint pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Koch is a commercial fisherman in Erie County, Ohio, and the owner of White’s Landing Fisheries, Inc. Koch and White’s Landing, which is not a party to this appeal, brought this suit after the Ohio Department of Natural Resources (ODNR), Division of Wildlife, amended a rule to limit seine commercial fishing licensees’ ability to catch yellow perch. Koch and White’s Landing asserted claims under the Fifth Amendment’s Takings Clause, as well as breach of fiduciary duty and civil conspiracy claims, against ODNR, ODNR Director Mary Mertz and Division of Wildlife Chief Kendra Wecker in their individual and official capacities, the United States Fish and Wildlife Service (FWS), and Deb Haaland in her now-former official capacity as Secretary of the Interior. The district court dismissed with prejudice Koch’s claims against Ohio and the state officials. It dismissed his takings claims, reasoning that the Takings Clause does not protect the value of his fishing license. In the alternative, the court also concluded that sovereign immunity would bar each claim against Ohio and the state defendants, as state officials, even if the takings and state law claims did not fail on their own. The court also dismissed Koch’s state law claims because they were insufficiently pled. Finally, the district court dismissed, seemingly without prejudice, all claims against the federal defendants for defective service. We affirm in part the district court’s dismissal of Koch’s complaint based on sovereign immunity, which bars Koch’s takings and state law claims against Ohio and the state officials. Because we affirm based on the district court’s lack of subject matter jurisdiction, we reverse in part and remand with instructions for the district court to dismiss Koch’s claims without prejudice.

JULIA SMITH GIBBONS, Circuit Judge. Petitioner Phillip L. Jones, an Ohio prisoner sentenced to death, appeals the district court’s denial of his petition for writ of habeas corpus. Jones makes three arguments on appeal: first, that the trial court violated his Confrontation Clause rights by allowing two witnesses to testify to out-of-court statements made by his wife; second, that his trial counsel were ineffective by not presenting testimony from a forensic expert to counter the state’s expert during the guilt phase; and third, that his counsel were ineffective during the penalty phase of trial. For the foregoing reasons, we affirm the judgment of the district court and deny Jones’s petition for writ of habeas corpus.

Defendant, Dewayne Winslow, was convicted by a Knox County jury of possession of more than 0.5 grams of methamphetamine with intent to sell or deliver, possession of a firearm during a dangerous felony, failure to carry vehicle registration, and unlawful possession of a weapon. The trial court imposed an effective 17-year sentence to be served in confinement. On appeal, Defendant argues the trial court erred by denying his motion to suppress the narcotics and firearm found in his vehicle and by allowing the State to introduce Defendant’s prior drug conviction as evidence of intent. Upon review of the record, the briefs of the parties, and the applicable law, we affirm the judgment of the trial court.

The Defendant, Charlie M. Gardner, was convicted in May 1999 by a Davidson County Criminal Court jury of one count of first degree murder and two counts of reckless aggravated assault. State v. Gardner, No. M1999-02214-CCA-R3-CD, 2001 WL 306227, at *1 (Tenn. Crim. App. Mar. 30, 2001), perm. app. denied (Tenn. Oct. 1, 2001). The Defendant’s convictions were affirmed on appeal. Id. at *13. On March 11, 2025, the Defendant filed a motion to correct clerical errors in his judgments of conviction, which the trial court granted on April 11, 2025. The Defendant filed a motion for a new trial on May 12, 2025, arguing it was timely because it was filed within thirty days of the entry of his corrected judgments. The trial court summarily dismissed the Defendant’s motion for a new trial as untimely. The Defendant appeals. Discerning no error, we affirm.