APPELLATE COURT OPINIONS

A mother appeals the termination of her parental rights to her child. Because the
Department of Children’s Services declined to defend one ground, we reverse that ground.
In all other respects, we affirm.

This is an accelerated interlocutory appeal filed by the pro se petitioner relative to the underlying action involving sale of an automobile. Because the petitioner has not demonstrated a factual basis warranting recusal of the trial court judge, we affirm the judgment of the trial court denying the motion to recuse. 

The subject of an order of protection appeals the denial of a motion under Rule 60.02 of the Tennessee Rules of Civil Procedure to set aside a final order extending the order of protection. Discerning no reversible error, we affirm.

The parties to this appeal were divorced in Virginia, and the divorce decree provided that
they would alternate parenting time with their young child every three weeks. The mother
moved to Tennessee, and the father later moved to Minnesota. After residing in Tennessee
for ten months, the mother filed a petition in Tennessee seeking to have the Tennessee
court enforce the Virginia divorce decree with respect to her allegations of contempt and
modify the Virginia decree to name her primary residential parent. The father subsequently
sought to register the Virginia decree in Minnesota. After a hearing, the Tennessee court
found that Virginia had lost exclusive continuing jurisdiction because all parties had left
that state and that Tennessee now had jurisdiction to modify the divorce decree because it
qualified as the child’s home state. However, the Tennessee court declined to exercise its
jurisdiction upon finding that Minnesota would be a more convenient forum for the
litigation, primarily based on the fact that the Virginia divorce decree contained an
agreement of the parties stating that the child would be enrolled in school in Minnesota
upon reaching school age if the father was still residing there. The trial court dismissed
the petition and awarded the father a portion of his attorney fees. The mother appeals,
arguing, among other things, that the trial court erred in its analysis of the statutory factors
under the inconvenient forum statute, erred by dismissing her request for enforcement of
the Virginia decree, and erred by granting the father his attorney fees. We agree and reverse
the trial court’s order of dismissal and its award of attorney fees. This matter is remanded
for further proceedings consistent with this opinion.

Mother/Appellant appeals the termination of her parental rights to the minor child on the grounds of: (1) severe child abuse, Tenn. Code Ann. § 36-1-113(g)(4); and (2) failure to manifest an ability and willingness to assume custody, Tenn. Code Ann. § 36-1-113(g)(14). Appellant also appeals the trial court’s finding that termination of her parental rights is in the child’s best interest. Discerning no error, we affirm.

The plaintiff filed this action against a trial court judge who had presided over a prior lawsuit involving the plaintiff. The Shelby County Circuit Court (“trial court”) dismissed the plaintiff’s claims, determining that they were barred by judicial immunity. The plaintiff timely appealed. Because the plaintiff has failed to comply with Tennessee Rule of Appellate Procedure 27 and Tennessee Court of Appeals Rule 6, we dismiss this appeal.

In this interlocutory appeal, we hold that this Court’s holding in Coffman v. Armstrong International, Inc., 615 S.W.3d 888 (Tenn. 2021), does not mandate dismissal as a matter of law of the plaintiff’s failure-to-warn claims. Here, the plaintiff filed a product liability lawsuit under the Tennessee Products Liability Act against the defendant alleged manufacturer of a seatbelt extender. The lawsuit claimed that the defendant was required to warn of risks of using the seatbelt extender in combination with a child’s booster seat, manufactured by another defendant, but the defendant failed to do so. After a mistrial, the trial court granted permission for interlocutory appeal on the question of whether Coffman bars the plaintiff’s failure-to-warn claims for risks associated with using the defendant’s product with another manufacturer’s product. The Court of Appeals granted the interlocutory appeal and held that Coffman bars the plaintiff’s claims as a matter of law. We reverse the Court of Appeals and clarify that the holding in Coffman does not mandate dismissal of the plaintiff’s failure-to-warn claims as a matter of law. Accordingly, we reverse the judgment of the Court of Appeals and remand the case to the trial court for further proceedings.

In this appeal, we hold that this Court’s holding in Coffman v. Armstrong International, Inc., 615 S.W.3d 888 (Tenn. 2021), does not mandate dismissal as a matter of law of the plaintiff’s failure-to-warn claims. Here, the plaintiff filed a product liability lawsuit under the Tennessee Products Liability Act against the defendant manufacturer of a child’s booster seat. The lawsuit claimed the defendant was required to warn of risks of using the booster seat in combination with a seatbelt extender, manufactured by another defendant, but failed to do so. The defendant moved for summary judgment on the grounds that Coffman bars the plaintiff’s failure-to-warn claims for risks associated with using the defendant’s product with another manufacturer’s product. The trial court granted the defendant’s motion for summary judgment and dismissed the plaintiff’s claim. The Court of Appeals affirmed and held that Coffman bars the plaintiff’s claims as a matter of law. We reverse the Court of Appeals and clarify that the holding in Coffman does not mandate dismissal of the plaintiff’s failure-to-warn claims as a matter of law. Accordingly, we reverse and remand the case to the Court of Appeals for further proceedings.

A Knox County jury convicted the Defendant, Charles Raymond Locke, Jr., of second
degree murder, and the trial court imposed a twenty-five-year sentence. The Defendant
appeals, asserting that the trial court erred when it denied his motion to suppress his
statement to the police and that the trial court abused its discretion when it sentenced him
to serve twenty-five years in prison. After a thorough review of the record, we affirm the
trial court’s judgment.

Roddarrius Eugene Jenkins, the Defendant, was convicted of first degree felony murder, especially aggravated robbery, a Class A felony, and being a felon in possession of a firearm, a Class B felony, by a Davidson County Criminal Court jury.  See T.C.A § 39-13-202 (2018) (subsequently amended) (first degree murder); § 39-13-403 (2025) (especially aggravated robbery); § 39-17-1307 (2018) (subsequently amended) (felon in possession of a firearm).  On appeal, the Defendant contends that the trial court erred by (1) violating his Equal Protection rights by denying his motion to appoint a second attorney, (2) denying his motions to suppress his pretrial statements, (3) admitting the Defendant’s uncorroborated statements as evidence, (4) denying, at the close of the State’s proof, the Defendant’s request for a self-defense instruction, (5) restricting the scope of the codefendant’s cross-examination, and (6) finding enhancement factors applied to the Defendant’s sentence.  The Defendant also contends that the evidence is insufficient to support the Defendant’s convictions for felony murder and especially aggravated robbery.  We affirm the judgments of the trial court. 

Defendant, John Skidmore, III, pleaded guilty to fourth offense driving under the influence (“DUI”) and was sentenced to two years suspended to probation after serving 150 days incarcerated. Following a hearing on a probation violation warrant, the trial court partially revoked Defendant’s probation, ordered him to serve one year and six months at 100 percent, and extended his probation for an additional year. Upon Defendant’s filing a motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1, the trial court amended its prior revocation order and fully revoked Defendant’s probation. Defendant appeals and argues the trial court failed to place adequate findings on the record to justify its imposition of consequences for Defendant’s probation violation. After review, we affirm the judgment of the trial court.

In this disciplinary appeal, the lawyer must be disbarred.  The lawyer engaged in a years-long orchestrated effort on social media to publicly intimidate judges and justice system officials, and to inspire community fear and loathing against the justice system itself. She posted hyperbolic commentary on social media loaded with false allegations about judges and justice system officials, doxed judges and justice system officials, urged her social media followers to send them harassing messages, intimidated judges and justice system officials, spread disinformation and conspiracy theories, and flagrantly defied court orders.  Her public comments to social media followers indicated she wished physical harm to judges and justice system officials, prompting them to fear for their safety and that of their families.  And in defiance of a protective custody order and an Amber Alert for a child in danger, the lawyer enabled her client to evade law enforcement by supplying her client with a burner phone and hiding the client and her child inside the lawyer’s own home. All of these acts were connected to judicial proceedings in which the lawyer was participating. After lengthy disciplinary proceedings, a Board of Professional Responsibility hearing panel recommended disbarment, and on appeal the trial court agreed.  The lawyer appeals to this Court.  Here, the lawyer’s comprehensive efforts sought to intimidate judges and justice system officials, and to directly poison the well of justice.  Her conduct is a grave dishonor as a lawyer and demands the most severe sanction.  No judicial response short of disbarment would be acceptable. 

Petitioner, Bryiant C. Overton, appeals the denial of his petition for writ of error coram nobis.  He contends that the circuit court abused its discretion by re-characterizing his petition as one for coram nobis relief, by dismissing the petition as time-barred, and by treating prior post-conviction proceedings as a procedural bar.  Upon review, we affirm.   

This is an appeal from a divorce with no minor children. Appellant claims that the trial court erred in multiple ways when classifying and distributing the marital estate. Appellant has waived these arguments, however, by failing to comply with this Court’s briefing requirements. Appellant also asserts that the trial court erred in granting Appellee attorney’s fees when she did not request such an award in her complaint. Upon review, we determine that the trial court’s reasoning for awarding attorney’s fees over Appellant’s objection is unclear. We therefore vacate trial court’s judgment as to Appellee’s attorney’s fees and remand the matter for reconsideration in accordance with Rule 52.01 of the Tennessee Rules of Civil Procedure. We affirm the remainder of the judgment.

A Knox County jury convicted the Defendant, Michael Wayne Norton, of aggravated
kidnapping, rape, aggravated assault, and domestic assault, and the trial court sentenced
him to twenty years. On appeal, the Defendant contends that the evidence is insufficient
to sustain his convictions. After review, we affirm the trial court’s judgments.

The trial court granted the plaintiff’s motion to voluntarily dismiss her health care liability action against two defendants but retained jurisdiction to determine whether or not to award sanctions against the plaintiff’s attorneys. More than one year after the trial court entered the order of voluntary dismissal, but less than one year after the court entered an order on the sanctions issue, the plaintiff refiled her health care liability claims. The defendants filed a motion to dismiss, arguing that the plaintiff failed to refile her action within one year from the date the order of voluntary dismissal was entered. The trial court denied the motion based, in part, on its determination that the one-year statute of limitations did not commence until the date the sanctions order was entered because the first action did not conclude until then. Because we have determined that the one-year statute of limitations commenced on the date the court entered the order of voluntary dismissal, we reverse the trial court’s decision and remand for entry of an order granting the motion to dismiss.

The Defendant, Joseph Eugene Chestnut, Jr., was convicted by a Macon County jury of one count of first degree premeditated murder and four counts of aggravated cruelty to animals.  The trial court imposed an effective sentence of life imprisonment.  On appeal, the Defendant claims that the trial court erred by denying his motion to suppress the firearm seized during the warrantless search of his vehicle and that the evidence of premeditation is insufficient to support his conviction of first degree murder.  Following our review and pursuant to Tennessee Rule of Criminal Procedure 36, we remand for entry of a corrected judgment in Count One to correct a clerical error.  Otherwise, we affirm the judgments of the trial court.

The Defendant, Sarah Elaine Smith, pled guilty to two counts of attempted aggravated assault and one count each of reckless endangerment with a deadly weapon, leaving the scene of an accident involving personal injury or death, leaving the scene of an accident involving property damage in excess of $1,500, reckless driving, failure to exercise due care, and failure to maintain lane, for which the trial court imposed an effective sentence of one year of supervised probation. Following a restitution hearing, the trial court ordered the Defendant to pay $16,250 in restitution in installments of $200 per month. The Defendant appeals, arguing that the restitution award is unreasonable, that she will be unable to pay the full amount of the restitution award by the end of her probationary sentence under her current payment schedule, and that the trial court erred by failing to consider her financial resources and ability to pay the restitution award. Following our review, we reverse the trial court’s restitution order and remand for entry of a revised restitution order.