Tennessee v. Williams

Defendant Delawrence Williams was indicted for possession of over one-half gram of cocaine with the intent to sell or deliver. He filed a motion to suppress the evidence, arguing that probable cause had not been shown for the issuance of a search warrant. The Court of Criminal Appeals affirmed the trial court’s decision to deny the motion to suppress. The Supreme Court granted this interlocutory appeal to review: (1) whether the information used to obtain a search warrant to search the defendant’s residence was provided by a “citizen informant” and presumptively reliable; and (2) whether the information, if not provided by a “citizen informant,” nonetheless established probable cause under "Tennessee v. Jacumin," (778 S.W.2d 430 (Tenn. 1989)). After reviewing the record and applicable authority, the Supreme Court held: (1) that the trial court and the Court of Criminal Appeals properly granted the interlocutory appeal pursuant to Rule 9 of the Tennessee Rules of Appellate Procedure; and (2) that although the information used to obtain the search warrant for the defendant’s residence was not provided by a “citizen informant,” it established probable cause under the two-prong analysis in Jacumin. The judgment was therefore affirmed. View "Tennessee v. Williams" on Justia Law