Justia Tennessee Supreme Court Opinion Summaries

Four university football players were indicted for criminal charges arising out of the alleged rape of a university student. Petitioners, a group of media organizations and a citizens group, made a Public Records Act request to inspect the police department’s files regarding its investigation of the football players. The police department denied the request. Petitioners filed a petition against the police department seeking access to the requested records under the Tennessee Public Records Act. The Court of Appeals concluded that all of the requested materials were relevant to a pending or contemplated criminal action and were therefore exempt from public disclosure under Tenn. R. Crim. P. 16. The Supreme Court affirmed on different grounds, holding (1) during the pendency of a criminal case and any collateral challenges to any conviction, Rule 16 governs the disclosure of information, and only the defendants, not the public, may receive information contained in the police investigative files; and (2) based on Rule 16, Petitioners have no right to the requested information during the pendency of the criminal cases and any collateral challenges to any convictions. View "The Tennessean v. Metro. Gov’t of Nashville & Davidson County" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the admission into evidence of an autopsy report through the testimony of a medical examiner who did not perform the autopsy was not testimonial, so its admission into evidence did not violate Defendant’s rights under the Confrontation Clause; (2) the responding officer’s initial entry into Defendant’s home was justified by exigent circumstances, and the subsequent entry into the home by other officers was a continuation of the responding officer’s entry into the home, and therefore, the trial court properly denied Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting into evidence items that were not in plain view during the warrantless search, the error was harmless. View "State v. Hutchison" on Justia Law

Defendant was stopped after a police officer observed him cross the double yellow center lane lines with the two left wheels of his car. Defendant was subsequently charged with driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the arresting officer’s seizure of Defendant did not violate Defendant’s constitutional rights, and therefore, the trial court did not err in denying Defendant’s motion to suppress. View "State v. Davis" on Justia Law

Defendant was stopped after a police officer observed Defendant cross once and touch twice the fog line marking the outer right lane boundary on an interstate highway. Defendant was subsequently charged with alternative counts of driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the traffic stop of Defendant did not violate his constitutional rights because it was supported by reasonable suspicion. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err in admitting an autopsy report through the testimony of a medical examiner who did not perform the autopsy, as the autopsy report was not testimonial and therefore did not violate Defendant’s rights under the Confrontation Clause; (2) the warrantless search of Defendant’s home by officers who entered the home after the first responding officer’s initial entry into the home was lawful, and consequently, the trial court did not err by denying Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting items that were not in plain view, the error was harmless. View "State v. Hutchison" on Justia Law

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

Plaintiff brought a statutory retaliatory discharge claim in the circuit court against the City of LaFollette pursuant to the Tennessee Public Protection Act (TPPA). Plaintiff requested a trial by jury. The trial court determined that Plaintiff was entitled to a jury trial on his TPPA claim. The court of appeals reversed, concluding that the Governmental Tort Liability Act (GTLA) applies to claims brought against a municipality pursuant to the TPPA, thus requiring the claim to be tried without a jury. The Supreme Court affirmed on different grounds, holding (1) the GTLA does not apply to TPPA claims against governmental entities; but (2) there is no constitutional or statutory right to trial by jury for TPPA claims filed in the circuit court. View "Young v. City of Lafollette" on Justia Law

Plaintiffs, five death-sentenced inmates, filed a declaratory judgment action against the Commissioner of the Tennessee Department of Correction (TDOC) and other TDOC officials challenging the constitutionality and legality of a 2014 statute that designated electrocution as an alternative method of execution and the constitutionality of electrocution as a means of execution. Defendants filed a motion to dismiss, arguing that Plaintiffs’ claims should be dismissed as unripe because the inmates were not currently subject to execution by electrocution and because the use of that method of execution in Tennessee was contingent on hypothetical, future, and speculative events. The trial court denied the motion, concluding that the claims were ripe because Plaintiffs were in danger of being electrocuted “in Tennessee’s electric chair.” The Supreme Court reversed and dismissed Plaintiffs’ electrocution claims as unripe, holding that because Plaintiffs were not currently subject to execution by electrocution and will not ever become subject to execution by electrocution unless one of two statutory contingencies occurs in the future, their claims challenging the constitutionality of the 2014 statute and electrocution as a means of execution are unripe and nonjusticiable. View "West v. Schofield" 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