Justia Tennessee Supreme Court Opinion Summaries

Defendant was indicted on sixteen counts of animal cruelty for intentionally or knowingly failing to provide necessary food and care to horses on his farm. Defendant pleaded not guilty and filed an application for pretrial diversion, stating that he lacked a criminal history and claiming that the horses were sick when he received them. The assistant district attorney general denied the application, finding that the factors against granting pretrial diversion outweighed those in favor of granting pretrial diversion. Defendant filed a petition for writ of certiorari seeking judicial review. The trial court found no abuse of discretion, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding that the assistant district attorney general did not abuse his discretion in denying Defendant pretrial diversion. View "Stanton v. State" on Justia Law

Plaintiff was a tenured teacher who worked for Defendant, the Memphis City Schools Board of Education. After Plaintiff requested and was granted a substantial amount of sick leave but failed to return from that sick leave, Defendant dismissed Plaintiff without providing her with written charges or an opportunity for a hearing. Plaintiff filed a complaint alleging that her dismissal violated the Tennessee Teacher Tenure Act and her constitutional due process rights. The trial court granted Plaintiff's motion for partial summary judgment and awarded Plaintiff's reinstatement, back pay, compensatory damages for the actual harm she suffered, and attorney's fees. The court of appeals vacated the grant of summary judgment. The Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court, holding (1) although a tenured teacher's failure to return from sick leave may constitute cause for termination, there is no statute authorizing a board of education to deem it a constructive resignation or a forfeiture of tenure; and (2) accordingly, Defendant violated Plaintiff's rights under the Tenure Act and her constitutional due process rights. View "Thompson v. Memphis City Schs. Bd. of Educ." on Justia Law

Petitioner was sentenced to death in 1991 after pleading guilty to murder and rape. In 2010, Petitioner filed a petition seeking to reopen his post-conviction proceeding on the ground that he possessed new scientific evidence of his actual innocence. His evidence consisted of a newly-obtained I.Q. test score purporting to show he could not be executed because he was intellectually disabled. The trial court denied the petition, determining, as a matter of law, that Petitioner's I.Q. test score was not new scientific evidence of his actual innocence. The court of criminal appeals affirmed because the I.Q. test score did not amount to scientific evidence of actual innocence for the purpose of Tenn. Code Ann. 40-30-117(a)(2) and because Coleman v. State did not announce a new rule of constitutional law under section 40-30-117(a)(1). The Supreme Court affirmed, holding (1) the General Assembly, when it enacted section 40-30-117(a)(2), did not intend for the phrase "actually innocent of the offense" to include ineligibility for the death penalty because of intellectual disability; and (2) Coleman v. State does not establish a new rule of constitutional law that must be applied retroactively under section 40-30-117(a)(1). View "Keen v. State" on Justia Law

In 2000, an affidavit of complaint was issued charging "John Doe" with an aggravated rape that occurred in 1994. The affidavit led to the issuance of an arrest warrant. In 2008, law enforcement officers discovered that fingerprints taken from the scene of the crime matched those of Defendant. Later, police determined that the DNA profile of "John Doe" contained in the affidavit was that of Defendant, and a superseding indictment was issued in his name. Defendant was subsequently convicted of attempted aggravated rape. Defendant appealed, arguing that the "John Doe" warrant with the DNA profile was insufficient to identify Defendant and commence prosecution within the applicable statute of limitations. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) a criminal prosecution is commenced if, within the statute of limitations for a particular offense, a warrant is issued identifying the defendant by gender and his or her unique DNA profile; and (2) furthermore, a superseding indictment in the defendant's name provides the requisite notice of the charge. View "State v. Burdick" on Justia Law

Defendant was found guilty of one count of facilitation of aggravated burglary and two counts of theft of property. After finding the presence of one enhancement factor, the trial court imposed concurrent three-year sentences for each offense. The court of criminal appeals found the enhancement factor did not apply and reduced each of the sentences to two years. The Supreme Court reversed the sentence modification by the court of criminal appeals and reinstated the sentence imposed by the trial court, holding (1) a sentence imposed by a trial court should be upheld so long as it is within the appropriate sentencing range and is otherwise in compliance with the purposes and principles of the sentencing statute; and (2) notwithstanding the trial court's reliance on an erroneous enhancement factor in this case, its imposition of three-year sentences was supported by the reasons articulated in the record. View "State v. Bise" on Justia Law

An officer stopped Defendant for a traffic violation. When the officer ordered Defendant out of his vehicle to sign the citation, he observed what appeared to be a bag of cocaine on the floorboard of the driver's side. Charged with possession with intent to sell or deliver twenty-six grams or more of cocaine in a school zone, Defendant moved to suppress the evidence as the product of an unlawful seizure. The trial court sustained the motion, concluding that the request to exit the vehicle was not reasonably related to the stop. The court of criminal appeals affirmed. The Supreme Court reversed the order of suppression and remanded the cause for trial, holding than an officer, after making a lawful stop for a traffic violation, may routinely direct the driver outside of the vehicle. View "State v. Donaldson" on Justia Law

During a robbery, one of the defendants shot the victim in the leg. Although the bullet passed through the victim's leg, the wound required minimal medical treatment and did not cause the victim to suffer a loss of consciousness, extreme pain, disfigurement, or impairment. The defendants were convicted of especially aggravated robbery and aggravated robbery. The court of criminal appeals affirmed the convictions. The Supreme Court modified the convictions for especially aggravated robbery to convictions for aggravated robbery because the victim did not suffer a serious bodily injury as required by Tenn. Code Ann. 39-13-403. Remanded to the trial court for resentencing. View "State v. Farmer" on Justia Law

Employee was discharged after she filed complaints with the Equal Employment Opportunity Commission and a lawsuit against Employer alleging employment discrimination. Employee appealed the termination to the Metro Civil Service Commission (Commission) and eventually settled the appeal, receiving backpay and other consideration in exchange for her agreement not to accept future employment with the agency that discharged her. Employee subsequently filed a complaint against Employer alleging violations of the Civil Rights Act and Age Discrimination in Employment Act. The trial court granted summary judgment in favor of Employer, reasoning that Employee could not establish her termination constituted an adverse employment action because she had accepted backpay and agreed not to be reinstated as part of the settlement of her Commission appeal. The court of appeals affirmed. The Supreme Court reversed, holding that Employee's acceptance of the settlement did not preclude her from establishing that her termination constituted an adverse employment action for purposes of her federal retaliatory discharge claims. View "Perkins v. Metro. Gov't of Nashville & Davidson County" on Justia Law

After an investigatory stop and frisk, Defendant was charged with the unlawful possession of a handgun after a felony conviction and the unlawful possession of a handgun while under the influence of alcohol and was convicted on both counts. Defendant appealed, arguing that his motion to suppress evidence should have been granted. The court of criminal appeals affirmed. The Supreme Court reversed the judgments of conviction and dismissed the cause, holding that because the investigatory stop and frisk of Defendant was not supported by specific and articulable facts establishing reasonable suspicion that a criminal act was being or about to be committed, the trial court erred by failing to suppress the handgun found by the police and presented as evidence at trial. View "State v. Williamson" on Justia Law

Defendant was tried and convicted of two counts of first degree murder and sentenced to death for each offense. The court of criminal appeals affirmed. The Supreme court affirmed in part and reversed in part, holding (1) the trial court erred by admitting detailed evidence of a prior claim of child sex abuse and by allowing references to Defendant's refusal to submit to a polygraph examination; (2) the prosecutor committed misconduct during the opening statement and during the final arguments of both the guilty and penalty phases of the trial; (3) however, the errors were harmless, and therefore, the convictions were affirmed; but (4) because certain of the inadmissible evidence was particularly inflammatory and the prosecution made several inappropriate comments, the sentences of death must be set aside. Remanded for new sentencing hearings. View "State v. Sexton" on Justia Law