Justia Tennessee Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Phillips was convicted of offenses, including felony murder, attempted first-degree murder, aggravated rape, especially aggravated kidnapping, and especially aggravated burglary. The Court of Criminal Appeals modified the especially aggravated burglary conviction to aggravated burglary. Phillips sought post-conviction relief, asserting that his trial counsel was constitutionally ineffective by failing to seek suppression of various statements he made to police. The Court of Criminal Appeals affirmed the denial of relief.The Tennessee Supreme Court affirmed, clarifying the petitioner’s burden to establish prejudice when he alleges counsel was constitutionally ineffective for failing to file a motion to suppress on Fourth Amendment grounds: The petitioner must prove that his Fourth Amendment claim is meritorious and that there is a reasonable probability that the verdict would have been different absent the excludable evidence. Despite the Fourth Amendment concerns brought about by the Memphis Police Department’s use of a 48-hour hold policy, there is no proof that the probable cause determination was unreasonably delayed and Phillips’s arrest was supported by probable cause. Given the proof of his guilt, Phillips has not established a reasonable probability that his verdict would have been different had his statements to the police been suppressed. View "Phillips v. State of Tennessee" on Justia Law

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The Supreme Court affirmed the judgments of the trial court convicting and sentencing Defendant for multiple drug offenses that occurred in a drug-free zone within 1,000 feet of a city park, holding that the offenses were subject to the requirement to serve in full at least the minimum sentence for the appropriate range prior to release.Because Defendant's offenses occurred in a drug-free zone, the trial court imposed sentences that required full service of at least the minimum term within the appropriate sentencing range prior to release. The court of criminal appeals concluded sua sponte that the felony class reflected on the judgment for one conviction was incorrect. The Supreme Court reversed in part and affirmed the judgments of the trial court, holding (1) because the drug-free zone related to a public park, the offenses were not subject to a one-class enhancement; but (2) the offenses were subject to the requirement to serve in full at least the minimum sentence for the appropriate range prior to release. View "State v. Linville" on Justia Law

Posted in: Criminal Law
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In this interlocutory appeal, the Supreme Court held that the Tennessee Bureau of Investigation (TBI) lacked the authority to refuse to comply with a final expungement order issued by the trial court.After Plaintiff had successfully completed probation he petitioned for expungement of his records and paid the expungement fee. The trial judge entered an expunction order. After the order became final, Plaintiff learned that the TBI had continued to report the existence of one of the expunged charged offenses. Plaintiff sued the TBI seeking declaratory and injunctive relief. The trial court declined to grant either party's motion for partial judgment on the pleadings. The Supreme Court reversed and granted Plaintiff's motion for partial judgment on the pleadings, holding that Plaintiff's expunction order was res judicata and binding on the TBI. View "Recipient of Final Expunction Order v. Rausch" on Justia Law

Posted in: Criminal Law
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The Supreme Court vacated Defendant's convictions, holding that the trial court committed reversible error by allowing impeachment evidence of a material defense witness without sufficient evidence, and the error was not harmless.After a jury trial, Defendant was convicted of attempted second-degree murder and unlawful employment of a firearm. The court of criminal appeals affirmed, holding, as relevant to this appeal, that Defendant's right to a speedy trial had not been violated and that the trial court did not commit reversible error in allowing improper impeachment of a defense witness. The Supreme Court reversed, holding (1) Defendant was not denied a speedy trial; but (2) the trial court's error in allowing improper impeachment evidence was reversible error. View "State v. Moon" on Justia Law

Posted in: Criminal Law
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In this appeal concerning the revocation of Defendant's probation the Supreme Court affirmed the court of criminal appeals' decision affirming the judgment of the trial court revoking Defendant's probation and ordering him to serve the balance of his sentence, holding that a probation revocation proceeding ultimately involves a two-step inquiry.At issue was whether revocation proceedings are a one-step or two-step process and the appropriate appellate standard of review to be used in reviewing such determinations. The Supreme Court held (1) a probation revocation proceeding involves a two-step process; and (2) if the trial court has properly placed its findings on the record, the standard of review for probation revocations is abuse of discretion with a presumption of reasonableness. View "State v. Dagnan" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of premeditated murder, first-degree felony murder, and other crimes and his sentence of death but reversed the portion of the judgment of the court of criminal appeals vacating the application of the felony murder aggravating circumstance, holding that the trial court properly convicted and sentenced Defendant.The court of criminal appeals affirmed Defendant's convictions and sentences but vacated the application of the felony murder aggravating circumstance as to the felony murder conviction. The Supreme Court reversed the portion of the intermediate court's judgment that vacated the application of the felony murder aggravating circumstances to the felony murder conviction, holding (1) the trial court did not err by either removing or failing to remove prospective jurors for cause during individual voir dire based on their view on the death penalty; (2) there was sufficient evidence to support Defendant's convictions; (3) there was no error in the trial court's evidentiary rulings; and (4) Defendant's challenges to his death sentence were unavailing. View "State v. Miller" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's conviction of premeditated first-degree murder, holding that the evidence was sufficient to support the conviction and that the trial court did not reversibly err in admitting evidence related to gang membership.After a jury trial, Defendant was convicted of premeditated first-degree murder. The court of criminal appeals reversed and remanded the case for a new trial, holding (1) the evidence of premeditation was legally insufficient, and (2) the trial court abused its discretion in admitting certain pieces of evidence related to gang membership. The Supreme Court reversed, holding (1) the evidence was legally sufficient to sustain the conviction; and (2) there was no reversible error with respect to the trial court's admission of gang-related evidence or any other evidentiary issue raised by Defendant. View "State v. Reynolds" on Justia Law

Posted in: Criminal Law
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In this appeal in a capital case, the Supreme Court affirmed the decision of the court of criminal appeals affirming Defendant's convictions and sentence, holding that Defendant was not entitled to relief on his claims of error.After a second trial, a jury found Defendant guilty of first-degree premeditated murder, murder in the perpetration of robbery, and aggravated robbery. Defendant was sentenced to death. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar retrial on the felony murder count; (2) alleged prosecutorial misconduct in the first trial did not bar Defendant's retrial; (3) the trial court did not err in denying Defendant's motion to suppress, in admitting evidence of Defendant's prior convictions for rape and assault of the victim and in admitting evidence of Defendant's escape attempts; (4) imposition of the death penalty was not arbitrary; and (5) the sentence of death was neither excessive nor disproportionate. View "State v. Rimmer" on Justia Law

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The Supreme Court reversed the decision of the court of criminal appeals reversing the trial court's order denying Petitioner's motion to correct an illegal sentence under Tenn. R. Crim. P. 36.1, holding that Petitioner's sentence was voidable, not void and illegal.Petitioner pled guilty to possession of cocaine with intent to sell and possession of a firearm by a convicted felon. The firearm sentence was enhanced pursuant to the criminal gang enhancement statute. Thereafter, in State v. Bonds, 502 S.W.3d 118 (Tenn. Crim. App. 2016), the court of criminal appeals declared the criminal gang enhancement statute unconstitutional. Instead of filing a postconviction petition challenging his guilty plea Petitioner filed a motion to correct an illegal sentence. The trial court denied the motion. The court of appeals reversed, holding that Petitioner's sentence was rendered void and thus illegal under Bonds. The Supreme Court reversed, holding (1) under Taylor v. State, 995 S.W.2d 78 (Tenn. 1999), Petitioner's sentence was voidable, not void and illegal; and (2) therefore, Petitioner was not entitled to relief under Rule 36.1. View "State v. Reid" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the court of criminal appeals and vacated the decision of the trial court to grant Defendant's motion for judgment of acquittal as to an aggravated child neglect charge, holding that a reasonable jury could have found the necessary elements of the crime of aggravated child neglect.Following the death of her infant child, Defendant was convicted of reckless homicide and aggravated child neglect. The trial court granted Defendant's motion for judgment of acquittal as to the aggravated child neglect charge. The court of criminal appeals affirmed, concluding that the evidence was insufficient to prove that Defendant knowingly neglected her child. The Supreme Court reversed, holding that a reasonable jury could have concluded that Defendant knowingly neglected her child by not feeding her and her child died as a result. View "State v. Weems" on Justia Law

Posted in: Criminal Law