Justia Tennessee Supreme Court Opinion Summaries

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

Plaintiff initiated this lawsuit challenging the constitutionality of the “Tennessee Plan,” which governs the way in which judges of the Tennessee appellate courts are initially selected and thereafter stand for election. The court of appeals upheld as constitutional the Judicial Nominating Commission/gubernatorial appointment under the Tennessee Plan, the retention election portion of the Tennessee Plan, and the election of the Tennessee intermediate appellate court judges on a statewide basis. The Special Supreme Court vacated in part and affirmed in part the judgment of the court of appeals, holding (1) the issue of the constitutional validity of the Judicial Nominating Commission/gubernatorial appointment process under the Tennessee Plan was moot because by the time the Court heard oral argument, the judicial nominating commission portions of the Tennessee Plan were no longer in effect; (2) the retention election portion of the Tennessee Plan satisfies the constitutional requirement that the judges of the appellate courts be elected by the qualified voters of the State; and (3) the election of judges to the court of appeals and court of criminal appeals on a statewide basis does not violate the state Constitution. View "Hooker v. Haslam" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and aggravated burglary. Defendant appealed, challenging the sufficiency of the evidence. The court of criminal appeals affirmed the convictions and sentences, holding (1) the evidence of identification was sufficient as to both convictions; and (2) as to the aggravated burglary, the victim had not given his “effective consent” to the entry of the residence. The Supreme Court (1) affirmed the aggravated robbery conviction, holding that the identification evidence was sufficient as to both offenses; but (2) reversed the aggravated burglary conviction, holding that the evidence was insufficient as a matter of law to support the conviction because no reasonable factfinder could conclude that Defendant’s entry of the residence was without the victim’s “effective consent.” Remanded for a new trial on the lesser included offenses of aggravated criminal trespass and criminal trespass. View "State v. Pope" on Justia Law

Petitioner pled guilty to the felony charge of child neglect and to the misdemeanor charge of child abuse. About six months later, Petitioner for a petition for post-conviction relief, alleging that he received ineffective assistance of counsel based on trial counsel's failure to advise him of the immigration consequences of his plea and that his plea was unknowing and involuntary because the trial court failed to comply with Tenn. R. Crim. P. 11(b)(1)(J). The post-conviction trial court denied relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) trial counsel did not perform deficiently; and (2) the trial court's failure to comply with Rule 11(b)(1)(J) was harmless beyond a reasonable doubt. View "Garcia v. State" on Justia Law

At issue in this case was a law providing that citizens who appear in person to vote must present photographic proof of their identity. The statute authorized a photographic identification card issued by the State as a valid form of identification. Plaintiffs were two residents who attempted to vote in the primary election using photographic identification cards issued by the City of Memphis Public Library. The residents and City filed a declaratory judgment action arguing (1) the photographic identification requirement violated constitutional protections, and (2) the City qualified as an entity of the State authorized to issue valid photographic identification cards through its public library. The trial court denied relief. The court of appeals affirmed in part and reversed in part, holding (1) the photographic identification requirement did not violate constitutional principles, and (2) the photographic identification cards issued by the library complied with the statute for voting purposes. On appeal, the Supreme Court held (1) the issue pertaining to the library cards as photographic identification was moot because a change in the law precluded the use of photographic identification cards issued by municipalities or their libraries for voting purposes; and (2) the photographic identification requirement met constitutional scrutiny. View "City of Memphis v. Hargett" on Justia Law