Justia Criminal Law Opinion Summaries

In 2000, Defendant pleaded guilty to two counts of attempted rape. In 2010, the Supreme Court filed its opinion in Ward v. State, in which the Court held that trial courts, before accepting a guilty plea to a crime carrying a mandatory sentence of lifetime community supervision, must inform the defendant desiring to plead guilty of the consequence of lifetime supervision. In 2011, Defendant filed a petition for relief under the Post-Conviction Procedure Act, alleging that his guilty pleas were not knowing or voluntary because he had not been informed that he would be subject to lifetime community supervision. The trial court concluded that Defendant was entitled to post-conviction relief because (1) Ward should be applied retroactively, and (2) the applicable statute of limitations should be tolled on due process grounds. The court of criminal appeals reversed. The Supreme Court affirmed, holding (1) the holding in Ward does not require retroactive application, and therefore, Defendant was not entitled to tolling under Tenn. Code Ann. 40-30-102(b)(1); and (2) Defendant’s case did not warrant due process tolling. View "Bush v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and aggravated burglary. Defendant appealed, challenging the sufficiency of the evidence. The court of criminal appeals affirmed the convictions and sentences, holding (1) the evidence of identification was sufficient as to both convictions; and (2) as to the aggravated burglary, the victim had not given his “effective consent” to the entry of the residence. The Supreme Court (1) affirmed the aggravated robbery conviction, holding that the identification evidence was sufficient as to both offenses; but (2) reversed the aggravated burglary conviction, holding that the evidence was insufficient as a matter of law to support the conviction because no reasonable factfinder could conclude that Defendant’s entry of the residence was without the victim’s “effective consent.” Remanded for a new trial on the lesser included offenses of aggravated criminal trespass and criminal trespass. View "State v. Pope" on Justia Law

Petitioner pled guilty to the felony charge of child neglect and to the misdemeanor charge of child abuse. About six months later, Petitioner for a petition for post-conviction relief, alleging that he received ineffective assistance of counsel based on trial counsel's failure to advise him of the immigration consequences of his plea and that his plea was unknowing and involuntary because the trial court failed to comply with Tenn. R. Crim. P. 11(b)(1)(J). The post-conviction trial court denied relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) trial counsel did not perform deficiently; and (2) the trial court's failure to comply with Rule 11(b)(1)(J) was harmless beyond a reasonable doubt. View "Garcia v. State" on Justia Law

After a jury trial, Defendant was convicted of felony murder, first degree premeditated murder, and especially aggravated robbery. The trial court merged the murder convictions and imposed consecutive sentences of life for the murder and eighteen years for the especially aggravated robbery. As support for consecutive sentencing, the trial court ruled that Defendant qualified as a dangerous offender. The court of criminal appeals remanded to the trial court for a reconsideration of whether the sentences should be served concurrently or consecutively because the trial court had failed to specifically address underlying factors essential to a dangerous offender classification. The Supreme Court affirmed, holding (1) when a trial court places findings on the record to support its sentencing decision, the applicable standard of appellate review for a challenge to the imposition of consecutive sentences is abuse of discretion with a presumption of reasonableness; and (2) the trial court in this case failed to address the factors required to impose consecutive sentences based on the dangerous offender classification. Remanded for a new sentencing hearing. View "State v. Pollard" on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) the sentence of death was not excessive, disproportionate, or imposed arbitrarily; (3) the evidence was sufficient to support the jury's finding of the statutory aggravating circumstances beyond a reasonable doubt; and (4) the evidence supported the jury's finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt. View "State v. Pruitt" on Justia Law

After a bench trial, Defendant was convicted of two counts of attempted first degree murder and one count each of especially aggravated burglary, attempted aggravated robbery, and aggravated assault. In sentencing Defendant, the trial judge sentenced Defendant to consecutive twenty-five year sentences for each attempted first degree murder conviction. The court of criminal appeals (1) reduced one count of attempted first degree murder to attempted second degree murder, concluding that insufficient evidence supported the convictions, and modified the conviction of especially aggravated burglary to aggravated burglary; and (2) affirmed the other convictions. The Supreme Court affirmed in part and reversed in part, holding (1) there was sufficient evidence to support Defendant's convictions of two counts of attempted first degree murder; and (2) the trial judge did not err in imposing consecutive sentencing for the two attempted first degree murder convictions. View "State v. Dickson" on Justia Law

The issue before the Supreme Court in this case centered on the appropriate response when a trial court learns during a jury's deliberations that a juror exchanged Facebook messages with one of the State's witnesses during the trial. The trial court declined the defendant's request to hold a hearing to question the juror and witness to ascertain whether the communications required a mistrial. The appellate court concluded that the trial court did no err in declining the request for a hearing. The Supreme Court disagreed, however, vacated the judgment and remanded the case for a hearing. View "Tennessee v. Smith" on Justia Law

The issue before the Supreme Court in this matter centered on whether the petitioner was entitled to seek post-conviction relief from a civil judgment that found her in criminal contempt and imposed sanctions. The Court held that a criminal contempt adjudication under Tennessee Code Annotated 29-9-102 (2012) does not amount to a criminal conviction under the general criminal laws for the purposed of the Post-Conviction Procedure Act. Accordingly, the Court affirmed the Court of Criminal Appeals, which affirmed dismissal of the petition. View "Baker v. Tennessee" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law