APPELLATE COURT OPINIONS

This appeal involves a pregnancy discrimination claim asserted by an employee of a Nashville pizza restaurant. After refusing to accept a temporary reassignment requested by her employer, the employee quit her job and filed suit, alleging that her employer had discriminated against her in violation of the Tennessee Human Rights Act. The Chancery Court for Davidson County granted the employer ’s motion for directed verdict at the close of the employee’s proof after concluding that she had not made out a prima facie case for disparate treatment because of her pregnancy. The employee asserts on this appeal that the trial court erred by directing a verdict for the employer and by amending its final order on its own motion. We have concluded that the trial court correctly directed a verdict for the employer in this case and, therefore, affirm the trial court.

In this inverse condemnation action, Defendant Smith County appeals the trial court’s final judgment that suggested a $15,000 additur to the $7700 verdict rendered by the jury in favor of Plaintiff/Appellee Charles W. McKinney. We reverse the trial court’s judgment and remand this cause for a new trial on the issue of damages.

The defendant, Eric Larez, appeals his convictions in the Sullivan County Criminal Court on two counts of the sale of marijuana over one-half ounce and one count of the sale of over one-half gram of cocaine. He was sentenced as a Range I offender to two years confinement for each of the counts involving marijuana and nine years in that involving cocaine, all sentences to be served concurrently. He has filed a timely appeal of these convictions, alleging as error:

1. The trial court should have instructed the jury as to a“casual exchange.”
2. His rights to a speedy trial were violated by the delay of three and one-half years between his being charged with the offenses and being arrested following those charges.
3. The evidence was insufficient for a conviction as to the sale of a controlled substance.
4. He should have received a lesser or an alternative sentence.

Based upon our review, we affirm the judgment of the trial court.

This is an appeal by Ms. Bogan (Appellant) from an Order of the Chancery Court for Sullivan County which reduced Mr. Bogan’s (Appellee) alimony payments to her from $2,300 monthly to $945 monthly after Appellee’s retirement

I dissent from the judgment of the majority opinion “reinstat[ing] the prior award of $2,300 monthly alimony as provided in the parties’ original divorce decree.” In my opinion, the trial court did not abuse its discretion when it reduced Mr. Bogan’s monthly alimony obligation from $2,300 to $945. I would affirm the judgment of the trial court.

The appellant, Charles Edward Evans, appeals the Knox County Criminal Court’s order revoking his probation. In 1996, the appellant was convicted of one (1) count of selling less than 0.5 grams of cocaine and sentenced to eight (8) years as a Range II offender. The appellant was placed on probation by the Tennessee Department of Correction in February 1998. Subsequently, the state filed a petition to revoke the appellant’s probation, and after an evidentiary hearing, the trial court revoked the appellant’s probation. On appeal, the appellant claims that the trial court erred in revoking probation. After a review of the record before this Court, we affirm the judgment of the trial court pursuant to Rule 20 of the Tennessee Court of Criminal Appeals.

In this case we consider the proper standard of appellate review of a trial court’s denial of a motion to sever offenses under Tennessee Rule of Criminal Procedure 14(b)(1). For the reasons set forth below, we hold that a denial of a severance will only be reversed for an abuse of discretion. We also hold that the trial 1 The first count alleged that the appellant robbed a convenience store on November 29, 1995, at 8:00 p.m. The second count alleged that ten days later on December 9, 1995, the appellant robbed a video rental store at 7:10 p.m. Counts three and four of the indictment alleged robberies of two conve nience s tores on December 10, 199 5, occu rring at 4:00 p.m. an d 4:30 p.m . respec tively. 2 court in this case abused its discretion in denying a severance because the methods used to commit the offenses were not so materially distinct or unique as to rise to an inference of identity. Because we find that this abuse of discretion was not harmless, the decision of the Court of Criminal Appeals is reversed, and this case is remanded to the trial court for new trials.

We granted this appeal to determine whether stock in a closely-held corporation is a “security,” as defined by Tenn. Code Ann. § 47-8-102 (1992 Repl. & Supp. 1998)1, so that Chapter 8 of the Uniform Commercial Code (UCC) governs its sale or transfer. In Blasingame v. American Materials, Inc., 654 S.W.2d 659, 664 (Tenn. 1983), we concluded that closely-held stock was not a security within the meaning of Chapter 8 of the UCC. Because we have determined that the Official Comments of the 1977 version of the UCC, adopted by the Tennessee General Assembly in 1986, as well as the 1995 and 1997 amendments to the Code, overrule the reasoning in Blasingame, we now hold that closely-held stock is a security within the meaning of the UCC’s Chapter 8, and that the closely-held stock at issue in this case is governed by Chapter 8. Because the plaintiff cannot produce a signed writing that comports with the statute of frauds found at Tenn. Code Ann. § 47-8-319 (1992 Repl. & 1996 Repl.), nor can he satisfy one of the statutory exemptions, we reverse the judgments of the lower courts and find in favor of the defendant.
 

We granted the appeal in this case to address the proper application of Tennessee Rule of Criminal Procedure 14(b)(1), which is used to sever criminal offenses. For the reasons set forth below, we hold that the Court of Criminal Appeals erred in affirming the trial court’s denial of appellant’s motion to sever one count of child rape based upon a finding that the offense was part of a common scheme or plan. However, we also hold that the error is harmless because the appellant was acquitted on two of the three counts of child rape, and the evidence is entirely sufficient to support the appellant’s conviction on the remaining count. Accordingly, the judgment of the Court of Criminal Appeals is affirmed.