Justia Tennessee Supreme Court Opinion Summaries

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

A grand jury returned an indictment charging Defendant with especially aggravated burglary, especially aggravated kidnapping, first degree premeditated murder, and first degree felony murder. That same day, the grand jury returned a superseding indictment re-charging Defendant and her husband with the same offenses but adding a charge of criminal conspiracy as to each. After Defendant's step-daughter testified before the grand jury, a second superseding indictment was issued charging all offenses in the first indictment and adding a charge of accessory after the fact against Defendant's husband. After a jury trial, Defendant was convicted of aggravated burglary, especially aggravated kidnapping, attempted first degree premeditated murder, and first degree felony murder. Defendant appealed, arguing that the trial court should have dismissed the charges because of prosecutorial abuse of the grand jury process. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the prosecutor acted improperly by compelling the testimony of Defendant's step-daughter in the grand jury proceeding, and the trial court properly denied Defendant's motions alleging prosecutorial abuse of the grand jury process. View "State v. Mangrum" on Justia Law

Defendant was charged with two counts of aggravated robbery and one count of especially aggravated kidnapping. The trial court subsequently granted Defendant's motion for a judgment of acquittal on the robbery charges. After a jury trial, Defendant was convicted of especially aggravated kidnapping. The court of criminal appeals affirmed the conviction. The Supreme Court affirmed, holding that the trial court did not err (1) by failing to inform the jury that Defendant had been acquitted of the robbery charges after those charges were dismissed; and (2) by failing to instruct the jury on accomplice testimony or by instructing the jury on criminal responsibility. View "State v. Little" on Justia Law

While on patrol, a police officer observed a pick-up truck parked in a shopping center lot. Because the truck's headlights were turned on, the officer stopped her patrol car directly behind the truck and activated her blue lights. The officer then approached the truck, observed a beer can in a cup holder inside, and found Defendant in the driver's seat with the keys in the ignition. Defendant was subsequently convicted for his fourth offense of driving under the influence. The court of criminal appeals reversed, holding (1) Defendant had been seized by the officer at the time the blue lights were activated; and (2) at the time of the seizure, the officer lacked either probable cause or reasonable suspicion to support an investigatory stop. The Supreme Court affirmed, holding (1) the activation of blue lights will not always qualify as a seizure; and (2) the totality of the circumstances in this instance established that the officer seized Defendant absent probable cause or reasonable suspicion and was not otherwise acting in a community caretaking role. View "State v. Moats" on Justia Law

After a jury trial, Petitioner was convicted of especially aggravated kidnapping, aggravated assault, especially aggravated robbery, and other robbery charges. The Supreme Court denied Petitioner's appeal, and the U.S. Supreme Court denied Petitioner's petition for writ of certiorari. Petitioner filed a petition for postconviction relief after the statutory deadline had passed because his former attorney provided him the wrong deadline date and failed to give Petitioner his legal files until after the actual deadline had passed. The criminal court dismissed the petition as untimely. The court of criminal appeals affirmed. The Supreme Court reversed and remanded the case to the trial court so Petitioner could pursue his petition for postconviction relief, holding (1) the facts of this case reflected that Petitioner was effectively abandoned by his appellate attorney after his petition for writ of certiorari was filed in the U.S. Supreme Court; (2) this abandonment impeded Petitioner's otherwise diligent efforts to file a timely postconviction petition; and (3) therefore, the statute of limitations should be tolled. View "Whitehead v. State" on Justia Law

This case arose out of the death of Decedent and the ensuing dispute between his two sons from a previous marriage and Linda Carraway, whom he married two weeks before his death. Decedent's sons (Sons) challenged the validity of their father's marriage to Carraway (Wife) and the validity of the lost will that Wife sought to have established. Wife claimed she was the sole beneficiary of Decedent's estate pursuant to the terms of his will. After a jury trial, the jury found in favor of Sons. The court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) Wife waived her argument that Sons lacked standing to contest the validity of her marriage to their father; but (2) the trial court erred in allowing into evidence testimony regarding Wife's real property holdings and her late mother's will, and the error was not harmless. View "In re Estate of Smallman" on Justia Law

Petitioner was convicted of premeditated first degree murder, especially aggravated robbery, and setting fire to person property. Petitioner subsequently filed a petition for post-conviction relief based partly on numerous instances of his trial counsel's ineffective assistance. The post-conviction court dismissed the petition. The court of criminal appeals, however, reversed Petitioner's convictions and remanded for a new trial, determining that Petitioner's trial counsel had been ineffective with regard to limitations placed on the ability of a defense expert to testify that Petitioner's mental condition rendered him unable to premeditate. The Supreme Court (1) reversed the judgment of the court of criminal appeals and affirmed the judgment of the post-conviction court on this issue, holding that Petitioner was not entitled to relief based on the manner in which his trial counsel dealt with the limitations placed of the defense's expert witness; and (2) reversed the judgment of the lower courts denying Defendant's claim relating to trial counsel's failure to object to the requirement that Petitioner wear a stun belt during the trial and remanded that issue for a new hearing, as the record did not permit the reviewing court to determine whether trial counsel was deficient with regard to this issue. View "Mobley v. State" on Justia Law

Defendant was convicted in three separate trials of three sets of execution-style murders, of seven persons total. Defendant faced seven death sentences. Defendant elected not to seek a new trial in any of these cases. Subsequently, Defendant's sister filed a "next friend" petition in each of the murder cases, requesting the courts to declare Defendant incompetent, thereby enabling her to pursue post-conviction relief on Defendant's behalf. Each court denied the petitions, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial courts employed the correct legal standard for determining whether Defendant possessed the mental capacity to rationally forego seeking post-conviction relief; (2) Defendant's sister failed to prove that Defendant lacked the capacity to make rational decisions regarding the pursuit of post-conviction relief; and (3) in all future cases, Tennessee's court should employ the mental competency standard of Tenn. Sup. Ct. R. 28, 11(B) to address the issue of a prisoner's competency to pursue post-conviction relief. View "Reid v. State" on Justia Law