Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to death. Defendant’s conviction and sentence were affirmed on appeal. Defendant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court concluded that Defendant was not entitled to a new trial on the murder conviction but was entitled to a new sentencing hearing based on ineffective assistance of counsel. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to prove by clear and convincing evidence a reasonable probability that, but for the deficient performance of his trial counsel, the verdict of guilt for first degree murder would have been different. Remanded for a new sentencing hearing. View "Nesbit v. State" on Justia Law

Defendant was indicted on six counts of aggravated sexual battery and four counts of rape of a child for sexually abusing his stepdaughter. Defendant moved to suppress a surreptitiously-recorded conversation with the child’s mother, who was secretly cooperating with the police in their investigation of the abuse. The trial court denied the motion to suppress. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that the admission of Defendant’s recorded conversation with the child's mother did not violate his constitutional right against compelled self-incrimination because, under the totality of the circumstances, Defendant’s incriminating statements were admissible because they were made voluntarily. View "State v. Sanders" on Justia Law

After a jury trial, Defendant was found guilty of seven counts of rape of a child and two counts of aggravated sexual battery arising from the sexual abuse of his children. The court of criminal appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions because the State presented adequate evidence corroborating Defendant’s confession to his wife; (2) the trial court properly refused to suppress surreptitiously-recorded conversations between Defendant and his wife; (3) the trial court erred by admitting evidence that Defendant possessed and viewed adult pornography, but the error was harmless; and (4) any error in jury instructions given during trial that the mental state of “recklessness” could support a conviction for aggravated sexual battery was harmless beyond a reasonable doubt. View "State v. Clark" on Justia Law

A jury awarded $3 million in compensatory damages to Plaintiff after finding that Defendant, Plaintiff's employer, retaliated against Plaintiff in violation of Title VII of the Civil Rights Act of 1964 and the Tennessee Human Rights Act. The court of appeals reversed, concluding that Plaintiff failed to show that his supervisor knew of his protected activity before she took adverse action against him. The Supreme Court reversed the decision of the court of appeals, reinstated the jury verdict, and remanded, holding that the jury’s verdict was supported by material evidence from which the jury could infer that the supervisor knew that Plaintiff had filed a discrimination lawsuit when she engaged in retaliatory conduct against Plaintiff. View "Ferguson v. Middle Tenn. State Univ." on Justia Law

Sandy Womack was convicted and sentenced to a term of confinement with the Tennessee Department of Correction (TDOC). While Womack was housed at the Whiteville Correctional Facility in Hardman County, which was owned and operated by Corrections Corporation of America (CAA), a private entity, Womack filed suit against CAA in the Circuit Court for Davidson County, alleging that CAA had negligently failed to address his medical needs. CAA moved to dismiss the complaint or to transfer it to Hardeman County in accordance with Tenn. Code Ann. 41-21-803, asserting that section 41-21-803 “effectively localized actions brought by prisoners.” The Davidson County court granted the motion and transferred the case to Hardeman County. The court of appeals affirmed. The Supreme Court reversed, holding that section 41-21-803 did not apply to Womack’s lawsuit because his cause of action accrued while he was housed in the privately operated Whiteville Correctional Facility rather than in a facility operated by the TDOC within the meaning of the statute. View "Womack v. Corr. Corp. of Am." on Justia Law

Defendant was convicted of first degree premeditated murder, first degree felony murder, and related offenses. The trial court imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the court of criminal appeals did not err by affirming the trial court’s denial of Defendant’s motion to suppress statements he gave to law enforcement officers on the basis that the confessions were knowingly and voluntarily made; and (2) Defendant’s death sentence was not imposed arbitrarily, the evidence supported the trial court’s finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt, and the sentence of death was not disporportionate. Remanded for entry of a corrected judgment reflecting the trial court’s merger of Defendant’s convictions for first degree murder into a single conviction. View "State v. Freeland" on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of criminal appeals affirmed. The Supreme Court vacated Defendant’s conviction and sentence, holding (1) the lead prosecutor violated Defendant’s constitutional right against self-incrimination during final closing argument by making a remark that the jury necessarily would have taken to be a comment on Defendant’s exercise of her constitutional right not to testify; (2) the prosecution violated Defendant’s constitutional right to due process by failing to provide to the defense until after the trial the third statement a key witness gave to law enforcement officers investigating the murder; and (3) these constitutional errors were not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Jackson" on Justia Law

Petitioner entered best interest guilty pleas to attempted first degree murder, second degree murder, and especially aggravated robbery. Petitioner later filed a petition for post-conviction relief, claiming ineffective assistance of counsel and that his guilty pleas were not knowingly and voluntarily made. Petitioner requested that the post-conviction court issue subpoenas for his three co-defendants, who were incarcerated at the time, to testify at the post-conviction hearing. The post-conviction court granted the State’s motion to quash because the defendants were incarcerated. After a subsequent hearing, the post-conviction court denied post-conviction relief. The court of criminal appeals concluded that the post-conviction court erred in refusing to allow Petitioner to present witnesses in support of his claims, but that the error was harmless. The Supreme Court reversed, holding that the post-conviction court committed prejudicial error by applying an incorrect legal standard and by overlooking the relationship between the proffered testimony and Petitioner’s claim of ineffective assistance of counsel. Remanded. View "Taylor v. State" on Justia Law

Property Owners filed an action against Montgomery County, asserting a claim of regulatory taking under Tenn. Const. art. I, 21, for which they sought compensation pursuant to the inverse condemnation statute. The County filed a motion to dismiss for failure to state a claim. The trial court denied the motion. The Court of Appeals reversed in part and remanded, holding (1) the Property Owners’ regulatory takings claim should be dismissed because the Court had not yet recognized regulatory takings under the state Constitution; but (2) the Property Owners alleged facts sufficient to state a claim for inverse condemnation. The Supreme Court reversed the Court of Appeals’ judgment insofar as it reversed the trial court’s judgment and dismissed the Property Owners’ regulatory taking claim, holding (1) like the Takings Clause of the federal Constitution, Tenn. Const. art. I, 21 encompasses regulatory takings; and (2) the Property Owners’ complaint was sufficient to allege a state constitutional regulatory taking claim, for which they may seek compensation under Tennessee’s inverse condemnation statute. View "Phillips v. Montgomery County" on Justia Law

Defendant pled guilty to two counts of vehicular homicide and was sentenced to twenty-four years' imprisonment. Defendant twice appealed his sentence. On both appeals the court of criminal appeals remanded the case for resentencing, and on each remand the trial court imposed a twenty-four year sentence. No appeal was filed from the third sentencing order. Defendant subsequently filed a pro se petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance by failing to appeal the third sentencing order. At the post-conviction hearing, trial counsel testified that he and Defendant discussed a third appeal and that Defendant agreed that no appeal would be filed. The post-conviction court denied post-conviction relief, finding the testimony of trial counsel to be more credible than the testimony of Defendant and concluding that Defendant knew of his right to appeal and waived that right. The Supreme Court affirmed, holding (1) trial counsel’s failure to file a written waiver of appeal as required by Tenn. R. Crim. P. 37(d)(2) did not violate Defendant’s right to effective assistance of counsel; and (2) Defendant failed to prove by clear and convincing evidence his allegations of ineffective representation. View "Arroyo v. State " on Justia Law