Justia Tennessee Supreme Court Opinion Summaries

Mortgage Electronic Registration Systems, Inc. (MERS) brought this action to set aside a tax sale of real property, arguing that the county’s failure to provide it with notice of the sale violated his right to due process. The purchaser of the real property (Defendant) moved for judgment on the pleadings, asserting that MERS did not tender payment of the sale price plus the accrued taxes before bringing suit, as is statutorily required in a suit challenging the validity of a tax sale, and that MERS did not have a protected interest in the subject property. The trial court granted Defendant’s motion, concluding that MERS did not have an interest in the property. The Court of Appeals on the grounds that MERS lacked standing to file suit. The Supreme Court affirmed on different grounds, holding (1) MERS was not required to tender payment before filing this lawsuit; and (2) MERS acquired no protected interest in the subject property, and therefore, its due process rights were not violated by the county’s failure to notify it of the tax foreclosure proceedings or the tax sale. View "Mortgage Elec. Registration Sys., Inc. v. Ditto" on Justia Law

After a jury trial, Defendant was convicted of attempted voluntary manslaughter, aggravated assault, and false imprisonment. Concluding that the separate convictions for attempted voluntary manslaughter and aggravated assault did not violate double jeopardy, the trial court declined to merge any of the convictions and imposed consecutive sentences totaling twenty-six years, eleven months, and twenty-nine days. The Court of Criminal Appeals affirmed the convictions and sentences. Defendant appealed, arguing that his sentences for attempted voluntary manslaughter and aggravated assault should be merged based upon the former double jeopardy principles set out in State v. Denton. The Supreme Court affirmed, holding (1) due process safeguards do not prohibit the retroactive application of the double jeopardy standard adopted in State v. Watkins, which was decided after the date of Defendant’s offenses; and (2) under Watkins, Defendant was not entitled to relief. View "State v. Feaster" on Justia Law

Defendants were indicted for aggravated robbery, aggravated burglary, and especially aggravated kidnapping. A jury convicted Defendants of all charges. The trial court set aside the guilty verdicts for especially aggravated kidnapping and aggravated burglary, concluding that these convictions, in conjunction with the aggravated robbery convictions, violated due process principles. The Court of Criminal Appeals reversed and reinstated the verdicts, finding that separate convictions for each of the offenses did not violate principles of due process or double jeopardy. The Supreme Court remanded to the intermediate appellate court for consideration in light of the Court’s holding in State v. Cecil, which applied the requirement of a jury instruction pursuant to State v. White to cases already in the appellate process on the date White was issued. On remand, the Court of Criminal Appeals reached the same result. The Supreme Court affirmed, holding (1) a kidnapping charge accompanied by an aggravated burglary charge does not, standing alone, warrant a White jury instruction; and (2) the trial court erred by not instructing the jury pursuant to the requirements of White with regard to the kidnapping charge as accompanied by the aggravated robbery charge, but the error was harmless. View "State v. Alston" on Justia Law

After a grand jury returned a presentment against Defendant for possession of marijuana, Defendant posted bond and was released. Thereafter, a grand jury issued a nineteen-count presentment against Defendant charging her with multiple crimes, including attempted first degree murder. The State moved to revoke Defendant’s bail. The trial court granted the motion pursuant to Tenn. Code Ann. 40-11-141(b). The Court of Criminal Appeals reversed, holding that section 40-11-141(b) violated Tenn. Const. art. I, 15. The Supreme Court remanded the case to the trial court for a bail revocation hearing, holding (1) a defendant has a constitutional right to pretrial release on bail; (2) however, this right is not absolute, and a defendant may forfeit his or her right to bail by subsequent criminal conduct; and (3) before pretrial bail can be revoked, the defendant is entitled to an evidentiary hearing. View "State v. Burgins" on Justia Law

Defendant was indicted for driving under the influence and violating the open container law. Defendant moved to suppress all evidence discovered during the search of her car. The trial court granted the motion to suppress, concluding that one of the officers who, in response to a dispatch, had detained Defendant unlawfully prolonged the investigatory stop. The Court of Criminal Appeals affirmed. The Supreme Court set aside the order of suppression, holding that the officer had a reasonable basis for extending the stop by ten to fifteen minutes while awaiting the arrival of a second officer, and the duration of the investigatory detention did not exceed the “proper parameters.” Remanded. View "State v. Montgomery" on Justia Law

Defendant’s minor daughter was diagnosed with a rare form of cancer and died at the age of fifteen. Defendant was indicted for neglect of a child under the age of eighteen based on her failure to obtain adequate medical treatment for her daughter. Defendant moved to dismiss the charge, arguing that the “spiritual treatment” exemption within the child abuse and neglect statute, which precludes the prosecution of parents who, under certain circumstances, provide treatment through prayer alone in lieu of medical treatment, is unconstitutional. The trial court rejected Defendant’s constitutional claims and denied her motion to dismiss. After a trial, the trial court concluded that Defendant did not qualify for the spiritual treatment exemption and found her guilty of child neglect. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the spiritual treatment exemption is not unconstitutionally vague; and (2) because the exemption may be elided without invalidating the remainder of the child abuse and neglect statute, Defendant’s remaining constitutional challenges would not afford relief. View "State v. Crank" on Justia Law

After a jury trial, Petitioner was convicted of first degree premeditated murder for fatally shooting his wife. After Petitioner’s conviction was affirmed in direct appeal, Petitioner filed a petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance by deciding not to consult an expert to rebut the anticipated testimony of a prosecution expert and by not attempting to introduce a potentially favorable hearsay statement. The post-conviction court denied the petition. The Court of Criminal Appeals reversed. The Supreme Court reversed, holding that Petitioner did not receive ineffective assistance from his trial counsel with regard to the issues before the Court on appeal. Remanded. View "Kendrick v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated burglary and other charges. The trial judge did not expressly accept or approve of the jury’s verdict. After Defendant’s trial and before the sentencing hearing, the trial judge left the bench and a successor judge was designated. The designated judge held a sentencing hearing, sentenced Defendant, and transferred the matter to a different division for further proceedings. Defendant moved for a new trial, alleging that a successor judge could not act as the thirteenth juror because witness credibility was the “over-riding issue.” A successor judge conducted the hearing on the motion. The trial court denied the motion. The Court of Criminal Appeals reversed on the thirteenth juror issue. The Supreme Court reversed the judgment of the Court of Criminal Appeals and reinstated the judgments of the trial court, holding that the successor judge in this correctly determined that he could perform the function of the thirteenth juror and could independently weigh and assess the evidence adduced at Defendant’s trial so as to prevent a miscarriage of justice by the jury. View "State v. Ellis" on Justia Law

After Plaintiff was discharged from his position of Chief of Police for the City of Red Bank, he filed suit in the Chancery Court against the City, alleging statutory retaliatory discharge in violation of the Tennessee Public Protection Act (TPPA) and age discrimination in violation of the Tennessee Human Rights Act (THRA). The Chancery Court (1) granted the City’s request to transfer the case to the Circuit Court; (2) granted the City’s request to proceed without a jury on the TPPA claim, citing Young v. Davis, which held that the Governmental Tort Liability Act (GTLA) controls TPPA claims against governmental entities, and such claims must be tried without a jury in the manner prescribed by the GTLA; but (3) upheld Plaintiff’s request for a jury on his THRA claim. The Court of Appeals reversed, holding that the GLTA applies to claims brought against a municipality pursuant to the THRA, and therefore, Plaintiff’s THRA claim was required to be tried without the intervention of a jury. The Supreme Court reversed, holding that the GTLA did not govern Plaintiff’s THRA claim and that the Legislature has afforded a statutory right to trial by jury on THRA claims filed against governmental entities in chancery court. View "Sneed v. City of Red Bank" on Justia Law

Defendant was indicted for seven counts of rape of a child victim. Two weeks before trial, the State sought to offer as evidence a video recording of a statement made by the victim to a forensic interviewer pursuant to Tenn. Code Ann. 24-7-123. The trial court denied admission of the video recording, concluding (1) the enactment of section 24-7-123 intruded upon the inherent authority of the judiciary to regulate the admissibility of evidence; (2) the video-recorded statement qualified as hearsay evidence not admissible under any exception to the rule against the admission of hearsay evidence; and (3) the admission of the video recording would violate Defendant’s right to confront witnesses. The Court of Criminal Appeals denied the State’s request for an interlocutory appeal. The Supreme Court reversed, holding (1) section 24-7-123 does not unconstitutionally infringe upon the powers of the judiciary and is a valid legislative exception to the general rule against the admission of hearsay evidence; and (2) the admission of video-recorded statements does not violate a defendant’s right of confrontation so long as the child witness authenticates the video recording and appears for cross-examination at trial. View "State v. McCoy" on Justia Law