Justia Tennessee Supreme Court Opinion Summaries

After a bench trial, Defendant was convicted of two counts of attempted first degree murder and one count each of especially aggravated burglary, attempted aggravated robbery, and aggravated assault. In sentencing Defendant, the trial judge sentenced Defendant to consecutive twenty-five year sentences for each attempted first degree murder conviction. The court of criminal appeals (1) reduced one count of attempted first degree murder to attempted second degree murder, concluding that insufficient evidence supported the convictions, and modified the conviction of especially aggravated burglary to aggravated burglary; and (2) affirmed the other convictions. The Supreme Court affirmed in part and reversed in part, holding (1) there was sufficient evidence to support Defendant's convictions of two counts of attempted first degree murder; and (2) the trial judge did not err in imposing consecutive sentencing for the two attempted first degree murder convictions. View "State v. Dickson" on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) the sentence of death was not excessive, disproportionate, or imposed arbitrarily; (3) the evidence was sufficient to support the jury's finding of the statutory aggravating circumstances beyond a reasonable doubt; and (4) the evidence supported the jury's finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt. View "State v. Pruitt" on Justia Law

The issue for the Supreme Court's review in this matter centered on whether the return proof of service 412 days after issuance of the summons precluded a plaintiff from relying upon the original commencement of the lawsuit to toll the running of the statute of limitations. The Court concluded that the plain language of Tennessee Rules of Civil Procedure 3 and 4.03 did not condition the effectiveness of the original commencement to toll the statute upon prompt return of proof of service. The Court reversed the Court of Appeals who affirmed the trial court in dismissing the plaintiff's lawsuit. The case was remanded to the trial court to determine whether service of process took place within ninety days of the summons. If so, plaintiff could then rely on the original commencement of the suit to toll the statute of limitations. View "Fair v. Cochran" on Justia Law

The issue before the Supreme Court in this case centered on the appropriate response when a trial court learns during a jury's deliberations that a juror exchanged Facebook messages with one of the State's witnesses during the trial. The trial court declined the defendant's request to hold a hearing to question the juror and witness to ascertain whether the communications required a mistrial. The appellate court concluded that the trial court did no err in declining the request for a hearing. The Supreme Court disagreed, however, vacated the judgment and remanded the case for a hearing. View "Tennessee v. Smith" on Justia Law

The issue before the Supreme Court in this matter centered on whether the petitioner was entitled to seek post-conviction relief from a civil judgment that found her in criminal contempt and imposed sanctions. The Court held that a criminal contempt adjudication under Tennessee Code Annotated 29-9-102 (2012) does not amount to a criminal conviction under the general criminal laws for the purposed of the Post-Conviction Procedure Act. Accordingly, the Court affirmed the Court of Criminal Appeals, which affirmed dismissal of the petition. View "Baker v. Tennessee" on Justia Law

Employee suffered a right shoulder injury while working for Employer. After a benefit review conference in the Department of Labor and Workforce Development ended in an impasse, Employee filed suit for workers' compensation benefits. Prior to trial, Employer requested the appointment of an independent medical examiner pursuant to the medical impairment rating (MIR) process in Tenn. Code. Ann. 50-6-204(d)(5). Because the suit had already been filed, the trial court denied the request and subsequently awarded compensation to Employee. The Supreme Court vacated the judgment and remanded for consideration of the constitutionality of the MIR process. On remand, the trial court concluded (1) section 50-6-204(d)(5), which requires the courts to consider the opinion of an independent medical examiner under that section as presumptively accurate, is an unconstitutional infringement upon the powers of the judiciary; and (2) in the alternative, the statutory presumption was overcome in this case. The Supreme Court reversed in part, holding (1) the MIR process does not violate constitutional principles; and (2) the evidence in this case did not clearly and convincingly rebut the statutory presumption. Remanded. View "Mansell v. Bridgestone Firestone N.A. Tire, LLC" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of false imprisonment and assault and sentenced to concurrent sentences of six months. While Defendant's case was pending on appeal, the Supreme Court filed its opinion in State v. White, which requires trial courts to provide a more specific instruction on kidnapping charges as to whether the removal or confinement of a victim is essentially incidental to any accompanying offense. On appeal, the court of appeals affirmed, holding that although the White instruction was not given at trial, the jury was correctly instructed and the evidence was sufficient to support both convictions. The Supreme Court reversed the conviction for false imprisonment, holding that the omission of the White instruction was not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Cecil" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law

Defendant was arrested on federal and state charges and taken into federal custody. After a trial in federal court, Defendant was convicted. Defendant was subsequently indicted by a Gibson County grand jury on the related state charges. After he was sentenced in federal court, Defendant was transported to Gibson County for an arraignment. Defendant was arraigned and then transferred back into federal custody. Defendant filed a motion to dismiss the state indictment for violations of the Interstate Agreement on Detainers (IAD), articles III and IV. Under article IV, an official of one jurisdiction may seek custody of a prison serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be shuttled back to the original place of imprisonment before the trial. The trial court denied the motion, and Defendant entered a conditional guilty plea. The court of criminal appeals affirmed the trial court's denial of Defendant's motion to dismiss. The Supreme Court reversed, vacated Defendant's conviction, and dismissed the indictment against Defendant with prejudice, holding that article IV of the IAD was violated when Defendant was transferred back to the federal detention center before being tried for the state charges. View "State v. Springer" on Justia Law