Justia Criminal Law Opinion Summaries

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

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. Styles" on Justia Law

The Supreme Court reversed the decision of the Court of Criminal Appeals to remand this case and reinstated the post-conviction court's denial of Petitioner's petition for post-conviction relief, holding that the Court of Criminal Appeals was without authority under the Post-Conviction Procedure Act to remand this case for consideration of an issue that was not raised by either party.Petitioner pled guilty to attempted first-degree murder and especially aggravated robbery. Petitioner was sentenced to seventeen years' imprisonment to be served concurrently with a previously imposed federal sentence and consecutive to a state sentence. Petitioner later filed a petition for post-conviction relief. The post-conviction court denied the petition. The Court of Criminal Appeals affirmed the denial of the petition but remanded the case for an evidentiary hearing to consider whether Petitioner was advised of the consequences of entering a guilty plea based upon the agreement that his state sentence be served concurrently with his prior federal sentence. The Supreme Court reversed, holding that because Petitioner did not raise the concurrent sentencing issue in his post-conviction petition, during his hearing, or on appeal, the issue was waived. View "Holland v. State" on Justia Law

The Supreme Court remanded this matter to the trial court for a new post-conviction hearing before different judge, holding that the post-conviction judge should have recused himself even though Petitioner failed to file a motion for recusal because his impartiality might reasonably be questioned.After a second trial, Petitioner was convicted of first-degree premeditated murder. Petitioner timely filed a petition for post-conviction relief. The petition as assigned to Judge Lee V. Coffee, the same judge who presided over Petitioner's second trial. The post-conviction judge denied relief. Petitioner appealed, arguing that the post-conviction judge should have recused himself. The Court of Criminal Appeals affirmed, concluding that Petitioner's challenge to the judge's impartiality was waived because Petitioner failed to file a motion seeking the post-conviction judge's recusal. The Supreme Court reversed, holding that the post-conviction judge should have disqualified himself under Rule of Judicial Conduct 2.11, and therefore, Petitioner was entitled to a new hearing before a different judge on his petition for post-conviction relief. View "Cook v. State" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals concluding that Petitioner was entitled to postconviction relief based on trial counsel's failure to file a timely motion for new trial, holding that the postconviction court properly considered whether Petitioner was prejudiced by his trial counsel's deficiency, and the postconviction court did not err in concluding that Petitioner was not.In his postconviction petition, Petitioner claimed that his trial counsel was ineffective for failing to timely file a motion for new trial. The postconviction court concluded that trial counsel was deficient but that Petitioner was not prejudiced. The court of appeals reversed, holding that Petitioner was presumptively prejudiced by his counsel's deficiency. The Supreme Court reversed, holding (1) trial counsel's failure to timely file a motion for new trial does not require a presumption of prejudice, and this Court's decision to the contrary in Wallace v. State. 121 S.W.3d 652 (Tenn. 2003), is overruled; and (2) the postconviction court in this case properly denied Petitioner's request for postconviction relief. View "Howard v. State" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's conviction for voluntary manslaughter, holding that the trial court did not err in admitting acquitted-act evidence and that the portion of State v. Holman, 611 S.W.2d 411 (Tenn. 1981), holding otherwise is overruled.Holman prohibits the use of acquitted-act evidence against a defendant at a subsequent trial under all circumstances. On appeal, the court of criminal appeals held that the trial court committed reversible error in admitting evidence of a prior criminal offense for which Defendant was acquitted because the evidence should have been excluded under Holman. The Supreme Court reversed, holding (1) evidence of a defendant's conduct for which he was acquitted in a previous trial may be introduced in a subsequent trial on a different charge only after the evidence has met the requirements of Tenn. R. Evid. 404(b); (2) Holman is no longer good law; and (3) the trial court did not abuse its discretion in admitting the acquitted-act evidence for the limited purpose of proving Defendant's intent to harm the victim. View "State v. Jarman" on Justia Law

The Supreme Court reversed the decisions of the court of appeals and the trial court that a municipality's personnel manual gave a firefighter a property interest entitled to due process protection, holding that Plaintiff failed to demonstrate that he had a property interest entitled to protection under either the due process clause of the United States Constitution or the law of the land clause of the Tennessee Constitution.After Plaintiff was terminated from his employment as a firefighter he filed a petition for a writ of certiorari, arguing that his due process rights were violated. The trial court concluded that Plaintiff was entitled to partial summary judgment on his due process claim, holding that the City personnel manual constituted a contract and that the termination of Plaintiff's employment was based on inappropriate procedure. The court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff failed to demonstrate that he had a property interest entitled to protection under the Tennessee or the United States Constitutions. View "Keller v. Casteel" on Justia Law

The Supreme Court reversed the judgment of the Court of Criminal Appeals reversing Defendant's conviction of first-degree premeditated murder and remanding the case for a new trial, holding that the proof at trial did not fairly raise the issue of whether or not Defendant killed the victim in self-defense, and therefore, the trial court properly exercised its gate-keeping role in refusing to charge the jury on self-defense.In reversing Defendant's conviction, the Court of Criminal Appeals held that self-defense should have been charged and that the error was not harmless. The Supreme Court reversed, holding (1) it is the role of the trial court to make a threshold determination of whether self-defense has been fairly raised by the evidence and thus should be submitted to the jury; (2) the trial court correctly concluded that the evidence in this case did not fairly raise as an issue that Defendant reasonably feared imminent death or serious bodily injury to justify his use of deadly force; and (3) therefore, the trial court properly refused to instruct the jury regarding self-defense. View "State v. Benson" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court suspending a bonding company for violating a local rule of court requiring an agent of the bonding company to be present at court appearances of defendants for whom the bonding company serves as surety, holding that the local rule is valid and enforceable.The bonding company in this case conceded that it violated the local rule but asserted that the local rule was inconsistent with Tennessee statutes and was arbitrary and capricious. The court of criminal appeals concluded that the part of the local rule requiring an agent of the bonding company to attend all court appearances was arbitrary, capricious, and illegal. The Supreme Court reversed, holding (1) the local rule does not conflict with state statutes and is not arbitrary, capricious, or unreasonable; and (2) the trial court did not err by suspending the bonding company for violating the local rule. View "In re Cumberland Bail Bonding" on Justia Law

The Supreme Court affirmed the court of criminal appeals' judgment affirming Defendant's conviction for one count of second degree murder, an alternative count of first degree felony murder, especially aggravated robbery, and three counts of aggravated assault, holding that, while the trial court erred in admitting certain testimony, substantial justice did not require that plain error relief be granted.At issue was whether the trial court committed reversible error in allowing the State to elicit testimony about a statement made by a non-testifying codefendant whose trial was severed and whose statements were the subject of a motion in limine granted by the trial court. After he was convicted, Defendant filed a motion for new trial, arguing that the trial court erred in concluding that the doctrine of curative admissibility permitted the testimony and, for the first time, raising a contention that the testimony violated his constitutional right of confrontation. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the testimony should not have been allowed, but Defendant was not entitled to plain error relief on his claim that the trial court violated his constitutional rights of confrontation by permitting the testimony; and (2) Defendant was not entitled to relief on the claims he preserved for plenary review. View "State v. Vance" on Justia Law