Articles Posted in Tennessee Supreme Court

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The Supreme Court affirmed Defendant’s convictions of the premeditated and felony murder of Clarence James and the premeditated and felony murder of Lillian James and Defendant’s sentences of death, holding that no reversible error occurred during the proceedings below. Specifically, the Court held (1) Defendant was not denied his constitutional right to counsel; (2) the trial court did not abuse its discretion in admitting into evidence certain testimony; (3) the evidence was sufficient to support Defendant’s convictions; (4) the trial court did not err in denying the appointment of a mitigation expert; and (5) Defendant’s death sentences were appropriate and not excessive or disproportionate to the penalty imposed in similar cases. View "State v. Jones" on Justia Law

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The Supreme Court reversed Defendant’s conviction of attempted especially aggravated sexual exploitation of a minor, holding that the evidence was insufficient to support an inference that Defendant intended to record, and believed he would record, the minor victim engaged in a “lascivious exhibition” of her private body areas. In this case, Defendant hid a video camera in the minor victim’s bedroom and aimed it to record the area where the victim normally changed clothes. The victim was fully clothed when she returned to her bedroom, noticed the camera, and turned it off. Defendant was convicted of especially aggravated sexual exploitation of a minor, i.e., attempted production of child pornography. The Supreme Court reversed, holding (1) the evidence showed at most that Defendant intended to produce material that would include images of the minor victim engaged in everyday activities ordinarily performed in the nude; and (2) therefore, the evidence was insufficient to support a finding that Defendant attempted to produce material that would include a depiction of a minor in a lascivious exhibition of her private body areas, as required under Tennessee’s child sexual exploitation statutes and construed in State v. Whited, 506 S.W.3d 416 (Tenn. 2016). View "State v. Hall" on Justia Law

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The Supreme Court affirmed the judgment of the Court of Criminal Appeals affirming the decision of the trial court to revoke Defendant’s judicial diversion for refusing to admit certain facts during his sex offender treatment, holding that Defendant’s due process rights were not violated because he was not specifically informed in conjunction with his nolo contendere plea that his judicial diversion could be revoked if he refused to admit certain facts during his sex offender treatment. Defendant pled nolo contendere to one count of solicitation of a minor and was placed on judicial diversion with a one-year probationary term. Defendant was required to register as a sex offender and to participate in sex offender treatment but was discharged from his treatment program for noncompliance. Thereafter, the trial court revoked Defendant’s diversion, adjudicated him guilty, and extended his probation. The Supreme Court affirmed, holding that due process does not require that a sex offender placed on judicial diversion with a probationary period to be informed specifically in conjunction with his plea that his judicial diversion and probation may be revoked if he is discharged from sex offender treatment due to his refusal to acknowledge that he committed the elements of the offense to which he pled. View "State v. Albright" on Justia Law

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At issue in this appeal was what showing, if any, a defendant must make to prevail on a motion for reduction of sentence under Tenn. R. Crim. P. 35 where the defendant pleaded guilty without an agreement as to sentencing pursuant to Tenn. R. Crim. P. 11(c)(1)(B). Defendant pleaded guilty without an agreement as to sentence. The trial court granted Defendant’s Rule 35 motion and reduced his aggregate sentence. The Court of Criminal Appeals reversed, concluding that a defendant must present post-sentencing information or developments warranting a reduction of sentence to prevail on a Rule 35 motion. The Supreme Court reversed and reinstated the trial court’s judgment, holding (1) the standard applied by the Court of Criminal Appeals is limited to Rule 35 motions seeking reduction of specific sentences imposed in exchange for guilty pleas; and (2) the trial court did not abuse its discretion when it determined that Defendant’s initial sentence was excessive and granted Defendant’s Rule 35 motion. View "State v. Patterson" on Justia Law

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The Supreme Court accepted a question of law from the United States Court of Appeals for the Sixth Circuit and concluded that a defendant convicted of first-degree murder committed on or after July 1, 1995 and sentenced to life in prison under Tenn. Code Ann. 39-13-202(c)(3) may be released, at the earliest, after fifty-one years of imprisonment. The certified question in this case concerned the interpretation and application of the Tennessee sentencing statutes governing release eligibility of criminal defendants under Tenn. Code Ann. 40-35-501(h) and (i). After analyzing the statutes, the Supreme Court held that a defendant convicted of first-degree murder that occurred on or after July 1, 1995 may be released after service of at least fifty-one years if the defendant earns the maximum allowable sentence reduction credits. View "Brown v. Jordan" on Justia Law

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The Supreme Court affirmed Defendant’s conviction for aggravated assault but modified his sentence, holding that the evidence was sufficient to support the conviction but the trial court erred in sentencing Defendant to enhanced punishment because Defendant did not receive proper notice of the State’s intention to seek enhanced sentencing. Defendant was convicted of aggravated assault and sentenced as a career offender. Defendant unsuccessfully objected to his classification as a career offender based on the State’s failure to file a pre-trial notice of intent to seek enhanced punishment. In its oral sentencing findings, the trial court noted that Defendant had the requisite prior convictions to qualify as a career offender and that, in a prior case, the State had filed a proper notice. The court of appeals affirmed. The Supreme Court reversed the sentence and remanded for entry of a corrected judgment, holding (1) a new enhancement notice must be filed in a separate case that is wholly unrelated to a prior case in which the State provides such notice; and (2) having received no properly filed notice of the State’s intent to seek enhanced punishment, Defendant was entitled to relief. View "State v. Williams" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing death-sentenced inmates’ challenge to Tennessee’s current three-drug lethal injection protocol, holding that the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution or article I, section 16 of the Tennessee Constitution. This appeal was the third time the Supreme Court addressed the facial constitutionality of Tennessee’s lethal injection protocol. In the first two appeals the Court upheld the particular protocol in question. At issue in the instant appeal was Tennessee’s current three-drug protocol. The trial court dismissed the inmates’ complaint for declaratory judgment. The Supreme Court affirmed, holding (1) the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment; and (2) the majority of the other issues raised by the inmates on appeal were rendered moot, and the inmates were not entitled to relief on their remaining issues. View "Abdur'Rahman v. Parker" on Justia Law

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The question these consolidated cases presented for the Tennessee Supreme Court's review centered on whether the trial court erred in suppressing evidence seized from the defendants’ residences in the 19th Judicial District because the warrants were signed by a Judge of the 23rd Judicial District. The Court held that, in the absence of interchange, designation, appointment, or other lawful means, a circuit court judge in Tennessee lacks jurisdiction to issue search warrants for property located outside the judge’s statutorily assigned judicial district. Nothing in the record on appeal established the 23rd Judicial District Circuit Court Judge obtained jurisdiction to issue search warrants for property in the 19th Judicial District. As a result, the searches were constitutionally invalid. The judgment of the Court of Criminal Appeals, which upheld the trial court’s order granting the defendants’ motions to suppress was affirmed. View "Tennessee v. Frazier" on Justia Law

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The Supreme Court held that the Exclusionary Rule Reform Act (ERRA), Tenn. Code Ann. 40-6-108, represents an impermissible encroachment by the legislature upon the Supreme Court’s authority and responsibility to adopt exceptions to the exclusionary rule and therefore violates the Tennessee Constitution’s Separation of Powers Clause. Defendant was convicted to two counts of first degree premeditated murder and other crimes. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) in light of today’s holding that the ERRA is unconstitutional, the trial court erred when it denied Defendant’s motion to suppress in reliance on the ERRA; (2) a good-faith clerical error that results in an inconsequential variation between three copies of a search warrant required pursuant to Rule 41, in and of itself, does not entitle the moving party to suppression of the evidence collected pursuant to the warrant, and therefore, the trial court properly denied Defendant’s motion to suppress under this good-faith exception; and (3) Defendant’s remaining arguments on appeal did not warrant reversal of her convictions. View "State v. Lowe" on Justia Law

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The Supreme Court reversed the judgment of the trial court granting Defendant’s motion to suppress a blood sample drawn from Defendant pursuant to a search warrant because the arresting officer failed to leave a copy of the warrant with Defendant, holding that, under the facts and circumstances of this case, a good-faith exception should be applied to Tenn. R. Crim. P. 41’s exclusionary rule. The trial court granted Defendant’s motion to suppress the evidence obtained pursuant to the warrant on the basis of the exclusionary rule set out in Rule 41. The Court of Criminal Appeals affirmed. The Supreme Court reversed and remanded this matter to the trial court for further proceedings, holding that, given the specific facts of this case, a good-faith exception to Rule 41’s technical requirement that the officer executing a search warrant leave a copy of the warrant with the person searched should apply to this case. View "State v. Daniel" on Justia Law