Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree murder and tampering with physical evidence. The court of criminal appeals upheld Defendant's convictions and sentences. Defendant appealed, arguing (1) the trial court erred in declining his request for a jury instruction on defense of a third person, and (2) his abandonment of the murder weapon did not amount to tampering with physical evidence. The Supreme Court (1) affirmed Defendant's conviction for first degree murder, holding that the trial court properly denied Defendant's request for an instruction on defense of a third person; and (2) reversed Defendant's conviction for tampering with physical evidence, holding that Defendant did not "conceal" the murder weapon within the meaning of the relevant statute by tossing the murder weapon over a fence where it could be easily observed and recovered. View "State v. Hawkins" on Justia Law

Defendant pled guilty to reckless endangerment with a deadly weapon and theft of merchandise over five hundred dollars. The trial court sentenced Defendant as a Range II, multiple offender to three years on each count to be served concurrently. On appeal, Defendant argued that the trial court erred by failing to apply certain mitigating factors and by failing to grant probation or an alternative sentence. The court of criminal appeals, after declining to review the sentences because Defendant had failed to provide a transcript of the hearing on the guilty pleas, affirmed based upon a presumption that the evidence was sufficient to support the sentences. After granting an appeal because of conflicting opinions by the court of criminal appeals as to whether the absence of a transcript of a guilty plea submission hearing precludes appellate review on the merits, the Supreme Court ordered that the record be supplemented. The Court then affirmed the judgment of the trial court, holding that the record was adequate for a meaningful review of the sentences either with or without the transcript of the hearing on the guilty pleas, and Defendant was not entitled to relief. View "State v. Caudle" on Justia Law

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to life imprisonment. The court of criminal appeals affirmed the conviction and sentence but granted permission to appeal to address whether a discharged alternate juror's communication to the jury foreman entitled Defendant to a new trial. The Supreme Court affirmed, holding (1) the State presented sufficient, admissible evidence to rebut the presumption of prejudice that accompanies an improper outside influence upon the jury, and because there was no reasonable possibility that the note from the discharged alternate juror to the foreman affected the verdict, Defendant was not entitled to relief on this issue; (2) the trial court did not err with respect to the admission of evidence or its jury instructions; and (3) the evidence was sufficient to convict Defendant of first degree premeditated murder. View "State v. Adams" on Justia Law

Plaintiffs filed a claim against a county hospital (Hospital) alleging that the negligence of the hospital and its employees caused the death of their son. The claim was filed fifteen months after Plaintiffs' son's death. Hospital, a governmental entity, filed a motion to dismiss, arguing that the claim was filed outside the one-year statute of limitations of the Governmental Tort Liability Act (GTLA). Plaintiffs argued that their complaint was timely filed because Tenn. Code Ann. 29-26-121(c) extends the GTLA statute of limitations by 120 days. The trial court denied Hospital's motion to dismiss but granted an interlocutory appeal. The court of appeals affirmed the denial of the motion to dismiss. The Supreme Court reversed, holding that the 120-day extension provided by section 29-26-121(c) did not apply to Plaintiffs' claim brought under the GTLA. Remanded for entry of an order dismissing the complaint. View "Cunningham v. Williamson County Hosp. Dist." on Justia Law

A concrete truck collided with a shuttle bus used to transport passengers between an airport and a rental car facility. A passenger who was injured during the collision and his wife filed an action against the bus owner, bus manufacturer, manufacturer of the bus windows, and franchisor of the rental car business. Plaintiffs based their claims in negligence and products liability, arguing that the bus was unsafe because it did not have passenger seatbelts, had windows made of tempered glass, and provided perimeter seating instead of forward-facing rows. A jury found Plaintiffs had sustained damages but assessed 100 percent of the fault to the corporate owner of the concrete truck, which had previously settled with Plaintiffs. On appeal, the court of appeals held that federal law preempted the seatbelt and window-glass claims and ruled that the trial court erred by failing to grant a directed verdict on the perimeter-seating claim. The Supreme Court remanded. On remand, the court of appeals affirmed its prior judgment. The Supreme Court reversed, holding (1) the seatbelt and window-glass claims were not preempted by federal law; and (2) the evidence sufficiently demonstrated causation in fact as to the perimeter-seating claim. Remanded. View "Lake v. The Memphis Landsmen, LLC" on Justia Law

After a jury trial, Defendant was convicted of especially aggravated robbery and felony murder. Defendant appealed, asserting that the evidence was insufficient to support his convictions. The court of criminal appeals found the evidence was insufficient to support the defendant's conviction of especially aggravated robbery and remanded to the trial court for re-sentencing on Defendant's conviction of second degree murder. The State appealed. The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court, holding that the evidence was sufficient to support Defendant's convictions of especially aggravated robbery and felony murder.View "State v. Wagner" on Justia Law

Defendant, convicted of felony murder and sentenced to life in prison, appealed, alleging a number of errors in the conduct of the trial, particularly the trial court's failure to suppress a statement Defendant had made to the police. The court of criminal appeals held that the admission of the statement qualified as harmless error. The Supreme Court granted Defendant's application for permission to appeal in order to determine the propriety of Defendant's arrest and to consider whether the court of criminal appeals had used the appropriate standard of review in its harmless error analysis. The Supreme Court then affirmed the judgment, holding that the arrest of Defendant was supported by probable cause and there was no other prejudicial error during the course of the trial.View "State v. Echols" on Justia Law

Plaintiffs alleged that Davidson County Sheriff's officers arrested and wrongfully interrogated and detained them while officers investigated Plaintiffs' immigration status pursuant to the October 2009 Memorandum of Agreement (MOA) entered into between the Davidson County Sheriff's Office (DCSO) and the United States Immigration and Customs Enforcement (ICE). The MOA authorized selected DCSO personnel to perform certain immigration officer duties after being trained and certified by ICE. The Supreme Court accepted certification to answer whether the MOA violated the Charter of Nashville and Davidson County. The Court held (1) the MOA did not violate the Charter or any other state law cited by Plaintiffs; and (2) the Sheriff of Davidson County had authority under the Charter to perform the duties enumerated in the MOA.View "Renteria-Villegas v. Metro. Gov't of Nashville & Davidson County " on Justia Law

Defendant was indicted on four counts of theft. At trial, the trial court ruled that Defendant's prior misdemeanor convictions for passing worthless checks were admissible to impeach her credibility pursuant to Tenn. R. Evid. 609, which states that a conviction punishable by less than one year of imprisonment is admissible if the crimes involves dishonesty or false statement. Defendant elected not to testify, and the jury convicted her on three of the four counts of theft. The Supreme Court affirmed, holding that the crime of passing worthless checks involves an element of dishonesty or false statement and that the trial court did not abuse its discretion when it determined that Defendant's prior convictions could be used to impeach her credibility if she testified.View "State v. Russell" on Justia Law

After a jury trial, Defendant was convicted of premeditated first degree murder. During the penalty phase of the trial, Defendant refused to allow his lawyers to present mental health mitigation evidence. The trial court ruled that Defendant was competent to waive the presentation of expert mental health testimony. The jury sentenced Defendant to death. The court of criminal appeals affirmed Defendant's conviction and sentence. The Supreme Court affirmed, holding primarily that (1) a mentally competent defendant may waive the presentation of mitigation evidence during the penalty phase of a capital trial; (2) the trial court did not err in ruling that Defendant was mentally competent to waive the presentation of mitigation evidence; and (3) the death sentence in this case was not imposed in an arbitrary fashion and was not disproportionate to the penalty imposed in similar cases. View "State v. Johnson" on Justia Law