Justia Tennessee Supreme Court Opinion Summaries

Defendant pled guilty to reckless endangerment with a deadly weapon and theft of merchandise over five hundred dollars. The trial court sentenced Defendant as a Range II, multiple offender to three years on each count to be served concurrently. On appeal, Defendant argued that the trial court erred by failing to apply certain mitigating factors and by failing to grant probation or an alternative sentence. The court of criminal appeals, after declining to review the sentences because Defendant had failed to provide a transcript of the hearing on the guilty pleas, affirmed based upon a presumption that the evidence was sufficient to support the sentences. After granting an appeal because of conflicting opinions by the court of criminal appeals as to whether the absence of a transcript of a guilty plea submission hearing precludes appellate review on the merits, the Supreme Court ordered that the record be supplemented. The Court then affirmed the judgment of the trial court, holding that the record was adequate for a meaningful review of the sentences either with or without the transcript of the hearing on the guilty pleas, and Defendant was not entitled to relief. View "State v. Caudle" on Justia Law

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to life imprisonment. The court of criminal appeals affirmed the conviction and sentence but granted permission to appeal to address whether a discharged alternate juror's communication to the jury foreman entitled Defendant to a new trial. The Supreme Court affirmed, holding (1) the State presented sufficient, admissible evidence to rebut the presumption of prejudice that accompanies an improper outside influence upon the jury, and because there was no reasonable possibility that the note from the discharged alternate juror to the foreman affected the verdict, Defendant was not entitled to relief on this issue; (2) the trial court did not err with respect to the admission of evidence or its jury instructions; and (3) the evidence was sufficient to convict Defendant of first degree premeditated murder. View "State v. Adams" on Justia Law

After a jury trial, Defendant was convicted of especially aggravated robbery and felony murder. Defendant appealed, asserting that the evidence was insufficient to support his convictions. The court of criminal appeals found the evidence was insufficient to support the defendant's conviction of especially aggravated robbery and remanded to the trial court for re-sentencing on Defendant's conviction of second degree murder. The State appealed. The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court, holding that the evidence was sufficient to support Defendant's convictions of especially aggravated robbery and felony murder.View "State v. Wagner" on Justia Law

Defendant, convicted of felony murder and sentenced to life in prison, appealed, alleging a number of errors in the conduct of the trial, particularly the trial court's failure to suppress a statement Defendant had made to the police. The court of criminal appeals held that the admission of the statement qualified as harmless error. The Supreme Court granted Defendant's application for permission to appeal in order to determine the propriety of Defendant's arrest and to consider whether the court of criminal appeals had used the appropriate standard of review in its harmless error analysis. The Supreme Court then affirmed the judgment, holding that the arrest of Defendant was supported by probable cause and there was no other prejudicial error during the course of the trial.View "State v. Echols" on Justia Law

Plaintiffs alleged that Davidson County Sheriff's officers arrested and wrongfully interrogated and detained them while officers investigated Plaintiffs' immigration status pursuant to the October 2009 Memorandum of Agreement (MOA) entered into between the Davidson County Sheriff's Office (DCSO) and the United States Immigration and Customs Enforcement (ICE). The MOA authorized selected DCSO personnel to perform certain immigration officer duties after being trained and certified by ICE. The Supreme Court accepted certification to answer whether the MOA violated the Charter of Nashville and Davidson County. The Court held (1) the MOA did not violate the Charter or any other state law cited by Plaintiffs; and (2) the Sheriff of Davidson County had authority under the Charter to perform the duties enumerated in the MOA.View "Renteria-Villegas v. Metro. Gov't of Nashville & Davidson County " on Justia Law

Defendant was indicted on four counts of theft. At trial, the trial court ruled that Defendant's prior misdemeanor convictions for passing worthless checks were admissible to impeach her credibility pursuant to Tenn. R. Evid. 609, which states that a conviction punishable by less than one year of imprisonment is admissible if the crimes involves dishonesty or false statement. Defendant elected not to testify, and the jury convicted her on three of the four counts of theft. The Supreme Court affirmed, holding that the crime of passing worthless checks involves an element of dishonesty or false statement and that the trial court did not abuse its discretion when it determined that Defendant's prior convictions could be used to impeach her credibility if she testified.View "State v. Russell" on Justia Law

After a jury trial, Defendant was convicted of premeditated first degree murder. During the penalty phase of the trial, Defendant refused to allow his lawyers to present mental health mitigation evidence. The trial court ruled that Defendant was competent to waive the presentation of expert mental health testimony. The jury sentenced Defendant to death. The court of criminal appeals affirmed Defendant's conviction and sentence. The Supreme Court affirmed, holding primarily that (1) a mentally competent defendant may waive the presentation of mitigation evidence during the penalty phase of a capital trial; (2) the trial court did not err in ruling that Defendant was mentally competent to waive the presentation of mitigation evidence; and (3) the death sentence in this case was not imposed in an arbitrary fashion and was not disproportionate to the penalty imposed in similar cases. View "State v. Johnson" on Justia Law

Defendant was charged with and convicted of first-degree premeditated murder and abuse of a corpse. On appeal, the court of criminal appeals modified Defendant's first degree murder conviction to second degree murder. The court also affirmed the trial court's denial of Defendant's motion to suppress. Defendant appealed, contending that the trial court erred in denying his motion to suppress his statements to the police on the grounds that they were elicited in violation of his constitutional right to counsel and were involuntary. The Supreme Court vacated Defendant's convictions, holding (1) Defendant's statements were erroneously admitted into evidence because Defendant did not invoke his constitutional right to counsel and did not waive his Miranda rights; (2) the physical evidence discovered as a result of Defendant's statements was properly admitted into evidence because the totality of the circumstances showed that Defendant's statements were voluntary and not coerced; and (3) the State failed to establish that the erroneous admission of Defendant's statements was harmless beyond a reasonable doubt. Remanded. View "State v. Climer" on Justia Law

A confidential informant arranged a drug buy from a co-defendant. The co-defendant arrived in his truck with Defendant and another passenger. The three men were arrested, and a consensual search of the truck yielded 153 grams of cocaine and 8.6 grams of marijuana in close proximity to where Defendant had been seated. Police subsequently searched the co-defendant's residence, which yielded 293.5 grams of cocaine and drug paraphernalia. The State consolidated the weight of the cocaine and charged Defendant with possession with intent to sell 300 grams or more of cocaine, among other offenses. The jury convicted Defendant of possession with intent to sell 300 grams or more of cocaine and possession of drug paraphernalia. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a finding that Defendant constructively possessed the cocaine in the co-defendant's truck, but the evidence was insufficient to support a finding that Defendant constructively possessed the cocaine or drug paraphernalia in the co-defendant's residence; and (2) therefore, the cocaine conviction should be reduced to possession with intent to sell 26 to 299 grams of cocaine and the conviction for possession of drug paraphernalia should be vacated. Remanded for resentencing. View "State v. Robinson" on Justia Law

In a two-year period, more than eleven million cigarettes manufactured by an Indonesian cigarette manufacturer were sold in Tennessee. After the manufacturer withdrew its cigarettes from the United States market, the State suit the manufacturer, alleging that the manufacturer had failed to pay into the Tobacco Manufacturers' Escrow Fund as required by Tenn. Code Ann. 47-31-101 to -103. The trial court dismissed the suit for lack of personal jurisdiction over the manufacturer. The court of appeals reversed. At issue on appeal was whether Tennessee courts may exercise personal jurisdiction over the Indonesian manufacturer where the manufacturer's cigarettes were sold in the State through the marketing efforts of a Florida entrepreneur who purchased the cigarettes from an independent foreign distributor. The Supreme Court reversed, holding that Tennessee courts lacked personal jurisdiction over the manufacturer because the State failed to establish that the manufacturer purposely availed itself of the privilege of doing business in Tennessee. View "State v. NV Sumatra Tobacco Trading Co." on Justia Law