Justia Criminal Law Opinion Summaries

Articles Posted in Tennessee Supreme Court
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In this appeal concerning the revocation of Defendant's probation the Supreme Court affirmed the court of criminal appeals' decision affirming the judgment of the trial court revoking Defendant's probation and ordering him to serve the balance of his sentence, holding that a probation revocation proceeding ultimately involves a two-step inquiry.At issue was whether revocation proceedings are a one-step or two-step process and the appropriate appellate standard of review to be used in reviewing such determinations. The Supreme Court held (1) a probation revocation proceeding involves a two-step process; and (2) if the trial court has properly placed its findings on the record, the standard of review for probation revocations is abuse of discretion with a presumption of reasonableness. View "State v. Dagnan" on Justia Law

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The Supreme Court affirmed Defendant's conviction of premeditated murder, first-degree felony murder, and other crimes and his sentence of death but reversed the portion of the judgment of the court of criminal appeals vacating the application of the felony murder aggravating circumstance, holding that the trial court properly convicted and sentenced Defendant.The court of criminal appeals affirmed Defendant's convictions and sentences but vacated the application of the felony murder aggravating circumstance as to the felony murder conviction. The Supreme Court reversed the portion of the intermediate court's judgment that vacated the application of the felony murder aggravating circumstances to the felony murder conviction, holding (1) the trial court did not err by either removing or failing to remove prospective jurors for cause during individual voir dire based on their view on the death penalty; (2) there was sufficient evidence to support Defendant's convictions; (3) there was no error in the trial court's evidentiary rulings; and (4) Defendant's challenges to his death sentence were unavailing. View "State v. Miller" on Justia Law

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The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's conviction of premeditated first-degree murder, holding that the evidence was sufficient to support the conviction and that the trial court did not reversibly err in admitting evidence related to gang membership.After a jury trial, Defendant was convicted of premeditated first-degree murder. The court of criminal appeals reversed and remanded the case for a new trial, holding (1) the evidence of premeditation was legally insufficient, and (2) the trial court abused its discretion in admitting certain pieces of evidence related to gang membership. The Supreme Court reversed, holding (1) the evidence was legally sufficient to sustain the conviction; and (2) there was no reversible error with respect to the trial court's admission of gang-related evidence or any other evidentiary issue raised by Defendant. View "State v. Reynolds" on Justia Law

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In this appeal in a capital case, the Supreme Court affirmed the decision of the court of criminal appeals affirming Defendant's convictions and sentence, holding that Defendant was not entitled to relief on his claims of error.After a second trial, a jury found Defendant guilty of first-degree premeditated murder, murder in the perpetration of robbery, and aggravated robbery. Defendant was sentenced to death. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar retrial on the felony murder count; (2) alleged prosecutorial misconduct in the first trial did not bar Defendant's retrial; (3) the trial court did not err in denying Defendant's motion to suppress, in admitting evidence of Defendant's prior convictions for rape and assault of the victim and in admitting evidence of Defendant's escape attempts; (4) imposition of the death penalty was not arbitrary; and (5) the sentence of death was neither excessive nor disproportionate. View "State v. Rimmer" on Justia Law

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The Supreme Court reversed the decision of the court of criminal appeals reversing the trial court's order denying Petitioner's motion to correct an illegal sentence under Tenn. R. Crim. P. 36.1, holding that Petitioner's sentence was voidable, not void and illegal.Petitioner pled guilty to possession of cocaine with intent to sell and possession of a firearm by a convicted felon. The firearm sentence was enhanced pursuant to the criminal gang enhancement statute. Thereafter, in State v. Bonds, 502 S.W.3d 118 (Tenn. Crim. App. 2016), the court of criminal appeals declared the criminal gang enhancement statute unconstitutional. Instead of filing a postconviction petition challenging his guilty plea Petitioner filed a motion to correct an illegal sentence. The trial court denied the motion. The court of appeals reversed, holding that Petitioner's sentence was rendered void and thus illegal under Bonds. The Supreme Court reversed, holding (1) under Taylor v. State, 995 S.W.2d 78 (Tenn. 1999), Petitioner's sentence was voidable, not void and illegal; and (2) therefore, Petitioner was not entitled to relief under Rule 36.1. View "State v. Reid" on Justia Law

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The Supreme Court reversed the judgment of the court of criminal appeals and vacated the decision of the trial court to grant Defendant's motion for judgment of acquittal as to an aggravated child neglect charge, holding that a reasonable jury could have found the necessary elements of the crime of aggravated child neglect.Following the death of her infant child, Defendant was convicted of reckless homicide and aggravated child neglect. The trial court granted Defendant's motion for judgment of acquittal as to the aggravated child neglect charge. The court of criminal appeals affirmed, concluding that the evidence was insufficient to prove that Defendant knowingly neglected her child. The Supreme Court reversed, holding that a reasonable jury could have concluded that Defendant knowingly neglected her child by not feeding her and her child died as a result. View "State v. Weems" on Justia Law

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The Supreme Court reversed the judgment of the court of criminal appeals dismissing Defendant's appeal and dismissed Defendant's convictions for possession with the intent to deliver more than twenty-six grams of methamphetamine and possession of drug paraphernalia, holding that the initial search of Defendant's house during which law enforcement discovered illegal contraband was unlawful.Defendant pled guilty but specifically reserved a certified question of law pertaining to the legality of the search in this case. The court of criminal appeals dismissed the appeal, determining that the certified question was not dispositive because the evidence would have been admissible notwithstanding the search in question under the inevitable discovery doctrine. The Supreme Court reversed and dismissed Defendant's convictions, holding (1) the inevitable discovery doctrine did not apply in this case; and (2) the State did not carry its burden of proving that either exigent circumstances or voluntary consent justified their warrantless search of Defendant's home. View "State v. Scott" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of criminal appeals affirming Defendant's convictions for two counts of delivering marijuana and two counts of money laundering, holding that the evidence was insufficient to support one of the money laundering convictions.Specifically, the Supreme Court held (1) the evidence supporting the first money laundering conviction was legally sufficient; (2) the evidence was insufficient with respect to the second money laundering conviction; (3) Defendant's punishment for both delivery of marijuana and money laundering does not violate double jeopardy protections; and (4) the money laundering statute is not unconstitutionally vague by virtue of its use of the undefined phrase "carrying on." View "State v. Allison" on Justia Law

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The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's denial of Defendant's motion for recusal, holding that, for the reasons provided today in State v. Griffin, __ S.W.3d __ (Tenn. 2020), Defendant failed to establish that there was a reasonable basis to question the trial judge's impartiality.In this case, one of three decided today involving a trial judge who previously served as a deputy district attorney general in Knox County at the time the defendants in each case were indicted by the Knox County Grand Jury, Defendant moved for recusal, arguing that the trial judge previously had supervisory authority over his case as Deputy District Attorney General. The trial judge denied the motion for recusal, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that, as in Griffin, Defendant failed to establish that the trial judge's supervisory responsibilities in his role as Deputy District Attorney General were personal or substantial in that case. View "State v. Clark" on Justia Law

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The Supreme Court reversed the decision of the Court of Criminal Appeals reversing the trial judge's decision to deny Defendants' motion for recusal on the grounds that the trial judge had supervisory authority over their cases as Deputy District Attorney General, holding that the trial judge appropriately denied the motion to recuse in this case.The trial judge here served as a deputy district attorney general in Knox County at the time Defendants were indicted by the Knox County Grand Jury. The trial judge was subsequently appointed to serve as a trial judge in Knox County Criminal Court and assigned to Defendant's cases. Defendants moved for recusal. The trial judge denied the motions, but the Court of Criminal Appeals reversed. The Supreme Court reversed, holding that the trial judge did not err in denying the motion for recusal because a person of ordinary prudence in the judge's position, knowing all the facts known to the trial judge, would not find a reasonable basis for questioning the judge's impartiality. View "State v. Griffin" on Justia Law