Justia Tennessee Supreme Court Opinion Summaries

Three documents related to a criminal case in Davidson County were filed and sealed without a written order by the presiding judge, who subsequently recused herself. After the case was transferred to a new trial court, a news organization sought to intervene and unseal the documents, which included a motion for judicial disqualification and supporting affidavits. The documents were not listed on the public docket, and the clerk’s office explained that they were marked “Filed Under Seal” by the preparer, but no formal order authorized the seal.The Criminal Court for Davidson County allowed the news organization to intervene but denied its motion to unseal the documents. The trial court found that more compelling interests were at stake, including the risk of publishing unsupported claims, potential embarrassment or burden to involved persons, and possible delays or denials of due process. The court ordered that the documents remain sealed and later issued a separate order citing confidentiality under Supreme Court rules. The news organization then sought review in the Tennessee Court of Criminal Appeals, which denied both an extraordinary appeal and a writ of certiorari, concluding that interlocutory appeal was not available to media intervenors in criminal cases.The Supreme Court of Tennessee granted review to address the availability of interlocutory appeals for media intervenors and the standard for sealing judicial records. The court held that such appeals are available to media intervenors when judicial proceedings are closed or records are sealed. The court further ruled that sealing judicial records protected by the First Amendment requires a written order identifying a compelling interest and that the seal must be narrowly tailored. After conducting a de novo review, the court found no compelling interest justifying the seal and ordered the documents to be made public, reversing the Court of Criminal Appeals. View "State of Tennessee v. Johnson" on Justia Law

In February 1994, Tony Carruthers, along with James and Jonathan Montgomery, was involved in the murders of Marcellos Anderson, Delois Anderson, and Freddrick Tucker. The victims were killed and buried beneath a casket in a Memphis cemetery. The prosecution presented evidence at trial that Carruthers had planned the crimes in advance and discussed the murders with others. Multiple witnesses placed Carruthers at the scene, and there was testimony that he confessed to the murders. Carruthers was convicted of three counts of murder and sentenced to death. Over the years, he has repeatedly claimed innocence and sought relief through various post-conviction and habeas proceedings, including requests for DNA and fingerprint testing on evidence from the crime scene.After the Tennessee Supreme Court affirmed his convictions and sentences, Carruthers pursued post-conviction relief in state and federal courts, but these efforts were unsuccessful. He previously sought DNA testing under the Post-Conviction DNA Analysis Act of 2001 and the Post-Conviction Fingerprint Analysis Act of 2021, but the courts denied his motions, finding that the results would not have changed the outcome of his conviction or sentence. Most recently, less than two months before his scheduled execution, Carruthers filed a motion for last-minute DNA testing of fingernail scrapings and bindings from the victims. The post-conviction court denied the motion, finding he failed to meet the statutory criteria for DNA testing, and the Court of Criminal Appeals was set to review the case when the Tennessee Supreme Court assumed jurisdiction.The Supreme Court of Tennessee affirmed the post-conviction court’s judgment. The court held that Carruthers failed to meet the first and fourth statutory criteria under both the mandatory and discretionary provisions of the DNA Act: there was not a reasonable probability that favorable DNA results would have prevented his prosecution or conviction, and the motion appeared designed to unreasonably delay his execution. The court concluded there was no abuse of discretion in denying the motion for DNA testing. View "Carruthers v. State" on Justia Law

A Kentucky-based luxury car broker persuaded the owner of a Tennessee car dealership to wire over $80,000 for the purchase of a specific Mercedes vehicle. The broker, communicating through text messages and emails, sent an invoice and a bill of sale falsely representing ownership and authority to transfer the car. After receiving the funds, he neither delivered the vehicle nor returned the money. Instead, he spent portions of the funds on personal expenses, including a vacation. Despite multiple requests and promises to return the money, the broker did not fulfill his obligations.A Loudon County grand jury indicted the broker for theft of property over $60,000 under Tennessee law. The defendant moved to dismiss the indictment, arguing that Tennessee lacked territorial jurisdiction, but the Loudon County Criminal Court denied the motion. At trial, the defendant gave inconsistent testimony about his involvement. The jury found him guilty, and the trial court sentenced him to ten years, with part of the sentence to be served in prison and the remainder on probation, along with restitution. The defendant’s motion for a new trial was denied. On appeal, the Tennessee Court of Criminal Appeals affirmed the conviction, finding that territorial jurisdiction was proper because the crime was consummated in Tennessee and that the victim’s consent was ineffective because it was induced by deception.The Supreme Court of Tennessee reviewed the case and held that Tennessee courts had statutory territorial jurisdiction under Tennessee Code Annotated section 39-11-103(b) because the theft offense was consummated in Tennessee through electronic communications originating from Kentucky. The court also found that the evidence was sufficient to support the conviction, as the victim’s consent to transfer the funds was obtained through deception. The Supreme Court of Tennessee affirmed the judgment of the Court of Criminal Appeals. View "State of Tennessee v. Lacy" on Justia Law

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