Justia Tennessee Supreme Court Opinion Summaries

A police officer responded to a report of a car accident in a residential area during the early morning hours and found a vehicle partially in a yard, facing the wrong direction. The officer approached the vehicle and saw Ambreia Washington in the driver’s seat, with a handgun visible on the front passenger seat. After asking Washington to exit the vehicle, the officer inquired whether Washington was a convicted felon, to which Washington replied affirmatively. When Washington attempted to flee, the officer used a taser and placed him under arrest, seizing the handgun. Washington was indicted for unlawful possession of a firearm by a convicted felon and other charges.Washington moved to suppress both the handgun and his statement regarding his felony status. The Circuit Court for Madison County suppressed the statement due to a Miranda violation but denied the motion to suppress the handgun, finding it was properly seized under the plain view doctrine. At trial, Washington was convicted by a jury. On appeal, the Tennessee Court of Criminal Appeals affirmed the trial court’s rulings, concluding that the officer’s actions were justified under the community caretaking doctrine and that the seizure of the handgun was permissible under the plain view doctrine.The Supreme Court of Tennessee reviewed whether the officer’s warrantless seizure of the firearm was lawful. The court held that the seizure was constitutionally permissible under the plain view doctrine, even though the officer’s probable cause to seize the gun was based on Washington’s unwarned but voluntary admission of his felony status. The court clarified that such nontestimonial evidence derived from a voluntary but un-Mirandized statement need not be suppressed absent coercion. The judgment of the Court of Criminal Appeals was affirmed. View "State v. Washington" on Justia Law

Ms. Sokolosky pleaded guilty to two misdemeanors and received consecutive 11-month, 29-day sentences, which were suspended for supervised probation. In February 2020, an arrest warrant was issued for her alleged probation violations, including not reporting and not making scheduled payments. She was taken into custody in April 2022 and filed a motion to dismiss the warrant, arguing that the records were untrustworthy due to unethical practices by the private probation company. The trial court denied her motion, found her in violation of probation, and extended her supervision. She appealed the revocation order and the denial of her motion to dismiss.The Court of Criminal Appeals dismissed her appeal as moot, reasoning that since her sentence had expired and she was no longer in custody, there was no active controversy to resolve. The court found that the case no longer served as a means to provide judicial relief and distinguished it from State v. Rodgers, which involved the Juvenile Post-Commitment Act.The Supreme Court of Tennessee reviewed the case and disagreed with the Court of Criminal Appeals. The Supreme Court held that Ms. Sokolosky’s appeal was not moot because the probation violation could have adverse consequences even after the completion of her sentence, such as affecting future sentencing or bond decisions. The court cited State v. Rodgers, which held that probation violations could have subsequent adverse effects, thus maintaining a genuine and existing controversy. The Supreme Court reversed the decision of the Court of Criminal Appeals and remanded the case for consideration on the merits. View "State v. Sokolosky" on Justia Law

In 1987, Pervis Payne was convicted of two counts of first-degree murder and one count of assault with intent to commit first-degree murder, receiving two death sentences and a thirty-year imprisonment term. The court ordered the sentences to be served consecutively, anticipating potential future commutation of the death sentences to life sentences. Decades later, following a legal pathway established by the Tennessee legislature, Payne was adjudicated intellectually disabled, leading to the vacating of his death sentences and their replacement with life sentences. The trial court also ordered that Payne’s sentences be served concurrently, making him eligible for parole in 2026.The Shelby County Criminal Court adjudicated Payne intellectually disabled and vacated his death sentences, substituting them with life sentences. The court also revisited the consecutive sentencing determination and ordered the sentences to be served concurrently. The State appealed, and the Court of Criminal Appeals affirmed the trial court’s decision, holding that the trial court had discretion to consider the manner of service of the sentences after vacating the death penalty.The Supreme Court of Tennessee reviewed the case and held that the trial court lacked jurisdiction to realign Payne’s sentences. The court affirmed the modification of Payne’s death sentences to life imprisonment but vacated the part of the trial court’s judgment that ordered the sentences to be served concurrently. The court emphasized that once a criminal judgment becomes final, it may not be modified unless a statute or rule authorizes its modification. The court remanded the case to the trial court for further proceedings consistent with its opinion. View "State of Tennessee v. Payne" on Justia Law

The case involves a road-rage incident in Marion County, Tennessee, where William Rimmel, III, aggressively pursued Bobbie Burke on the interstate while riding his motorcycle. Rimmel eventually broke the passenger window of Burke’s car using the slide of a loaded handgun. Although Rimmel never fired the handgun or pointed it at Burke, she was unaware that the object used to break the window was a gun. A jury convicted Rimmel of attempted aggravated assault and felony reckless endangerment with a handgun.The Circuit Court for Marion County sentenced Rimmel to two years of probation for the attempted aggravated assault conviction and one year of probation for the reckless endangerment with a handgun conviction, among other sentences for misdemeanor convictions. Rimmel's motions for a new trial and judgment of acquittal were denied. On appeal, the Court of Criminal Appeals affirmed the convictions, holding that a rational juror could conclude that Rimmel took a substantial step toward causing Burke to reasonably fear imminent bodily injury and that his conduct created a reasonable probability of danger.The Supreme Court of Tennessee reviewed the case and affirmed Rimmel’s conviction for attempted aggravated assault, concluding that the evidence showed Rimmel intended to place Burke in reasonable fear of imminent bodily injury by using a handgun and took a substantial step toward doing so. However, the court reversed Rimmel’s conviction for felony reckless endangerment with a handgun, finding that the evidence did not establish that Rimmel’s conduct placed Burke in imminent danger of serious bodily injury or death. The court dismissed the indictment for felony reckless endangerment and remanded the case for further proceedings. View "State v. Rimmel" on Justia Law

In this case, the defendant was convicted in 2022 for unlawful possession of a firearm after having been previously convicted of a felony crime of violence. The State introduced a certified judgment of conviction for the defendant’s 2017 robbery conviction, and the trial judge instructed the jury that robbery is a crime of violence. However, robbery is not included in the statutory definition of crimes of violence under Tennessee law. The defendant received a ten-year sentence.The Court of Criminal Appeals affirmed the conviction, concluding that robbery is a crime of violence despite its absence from the statutory definition. The defendant appealed, arguing that the evidence was insufficient to support his conviction because the State failed to establish that robbery was a crime of violence.The Supreme Court of Tennessee reviewed the case to determine whether robbery is encompassed within the statutory definition of “crime of violence” and whether the evidence at trial was sufficient to support the conviction. The Court concluded that the statutory list of crimes of violence is illustrative, not exhaustive, and that robbery can be considered a crime of violence. However, the Court held that whether a specific robbery is a crime of violence is a question for a properly instructed jury, not the trial judge.The Court found that the State did not present sufficient evidence for a reasonable jury to conclude that the defendant’s prior robbery was a crime of violence. Therefore, the Supreme Court of Tennessee reversed, in part, the decision of the Court of Criminal Appeals, vacated the trial court’s judgment on Count 1, and remanded the case for entry of a new judgment reducing the conviction to a Class E felony and for further proceedings consistent with the opinion. View "State v. Curry" on Justia Law

During a routine traffic stop, law enforcement conducted an open-air sniff using a drug-sniffing canine. The canine alerted to the vehicle, leading officers to search it without a warrant under the automobile exception. Inside a backpack, they found marijuana, a loaded handgun, Ziploc bags, and a scale. The defendant, a passenger, was indicted for possession of marijuana with intent to manufacture, sell, or deliver; possession of a firearm with intent to go armed during the commission of a dangerous felony; and possession of drug paraphernalia. The defendant moved to suppress the evidence, arguing the canine could not distinguish between legal hemp and illegal marijuana.The trial court granted the motion to suppress and dismissed the charges, finding the canine's reliability was not established due to its inability to differentiate between hemp and marijuana. The Court of Criminal Appeals reversed, holding that the smell of illegal marijuana provides probable cause to search a vehicle and that law enforcement had probable cause based on the totality of the circumstances.The Supreme Court of Tennessee reviewed the case and clarified that a positive alert from a drug-sniffing canine does not establish a per se rule of probable cause but should be considered within the totality of the circumstances. The court held that a positive indication from a drug-sniffing canine may still contribute to a finding of probable cause despite the legalization of hemp. Examining the totality of the circumstances, the court concluded that law enforcement had probable cause to search the vehicle. The Supreme Court of Tennessee affirmed the judgment of the Court of Criminal Appeals, reinstating the indictments against the defendant and remanding for further proceedings. View "State v. Green" on Justia Law

A prisoner filed a petition for a writ of error coram nobis, a legal order allowing a court to correct its original judgment, long after the one-year limitations period had expired. The petition was based on new evidence that the prisoner claimed demonstrated his actual innocence. The coram nobis court held a hearing and determined that the new evidence did not show that the prisoner was actually innocent of the crimes of which he was convicted. As a result, the court dismissed the petition as untimely.The Court of Criminal Appeals reversed the coram nobis court's decision, arguing that the prisoner had met the requirements for tolling, or delaying, the statute of limitations. The appellate court remanded the case for a hearing on the allegations in the petition.The Supreme Court of Tennessee disagreed with the appellate court's decision. The Supreme Court held that if a petition for a writ of error coram nobis is not timely filed and seeks tolling of the statute of limitations, it must be based on new evidence that clearly and convincingly shows that the petitioner is actually innocent of the underlying crime. The court found that the prisoner's new evidence did not meet this standard. Therefore, the Supreme Court reversed the decision of the Court of Criminal Appeals and affirmed the decision of the coram nobis court, dismissing the petition as untimely. View "Clardy v. State" on Justia Law

The Supreme Court of Tennessee heard the appeal of Tony Thomas and Laronda Turner, both convicted of three counts of first-degree premeditated murder stemming from a 2015 triple homicide in Memphis. The defendants were members of the Vicelords gang, and the murders were allegedly conducted in retaliation for a previous killing. Their trial relied heavily on the testimony of co-defendant Demarco Hawkins, whose trial was severed and who testified against them. Mr. Thomas and Ms. Turner appealed their convictions, alleging that the prosecution breached the requirements of Brady v. Maryland by failing to produce inconsistent statements made by Mr. Hawkins, and that the evidence was insufficient to support Ms. Turner’s murder convictions.The Supreme Court found that the State did not breach its obligations under Brady with regard to Mr. Thomas. However, the Court determined that the evidence was insufficient to sustain Ms. Turner’s convictions because Mr. Hawkins’ testimony was not adequately corroborated, leading to a reversal of her convictions. In addition, the Court abolished Tennessee’s common law accomplice-corroboration rule, which required some level of independent corroboration for accomplice testimony to be used in securing a conviction, but only applied this change prospectively. View "State v. Thomas" on Justia Law

A man, David Wayne Eady, who was charged with multiple robberies in Nashville over a month, appealed the decision of the Court of Criminal Appeals which denied his motion to disqualify the District Attorney General’s Office from prosecuting his case. Eady argued that the District Attorney General's office should be disqualified because the District Attorney had represented him in a previous case approximately thirty years earlier. The Supreme Court of Tennessee disagreed, finding that the District Attorney did not have an actual conflict of interest under the Rules of Professional Conduct because the current case and the previous case were not "substantially related." The court also rejected the defendant’s argument that the appearance of impropriety should disqualify the District Attorney General’s Office, noting that the Rules of Professional Conduct did not retain the concept of appearance of impropriety.Eady also argued that his trial was improperly conducted as a single trial for multiple offenses under the theory that the separate crimes were all parts of a larger, continuing plan. The Supreme Court of Tennessee agreed with Eady on this point, finding that the trial court erred in denying his motion to sever the offenses. The court held that the evidence did not support a finding that the offenses were parts of a larger, continuing plan, and remanded the case for a new trial on one of the counts. View "State v. Eady" on Justia Law

The Supreme Court affirmed the decision of the court of criminal appeals reversing the trial court's sentence imposed in connection with Defendant's plea of guilty to vehicular homicide by intoxication and other offenses, holding that the clear and precise language of the 2017 amendment to the probation eligibility statute, Tenn. Code Ann. 40-35-303, prohibits all forms of probation for a defendant convicted of vehicular homicide by intoxication.Defendant pleaded guilty to vehicular homicide by intoxication, aggravated assault, resisting arrest, and driving without a license. The trial court imposed a sentence of ten years in prison, largely suspended to probation with periodic weeks of confinement for the first three years. The court of criminal appeals reversed and ordered Defendant to serve the full sentence in confinement, concluding that the 2017 amendment to the probation eligibility statute expressly prohibits probation of any kind for criminal defendants convicted of vehicular homicide by intoxication. The Supreme Court affirmed, holding that the clear and precise language of section 40-35-303 prohibits defendants convicted of vehicular homicide by intoxication from receiving any form of probation, including periodic and split confinement sentences. View "State v. Robinson" on Justia Law