Justia Tennessee Supreme Court Opinion Summaries

Defendant was stopped after a police officer observed him cross the double yellow center lane lines with the two left wheels of his car. Defendant was subsequently charged with driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the arresting officer’s seizure of Defendant did not violate Defendant’s constitutional rights, and therefore, the trial court did not err in denying Defendant’s motion to suppress. View "State v. Davis" on Justia Law

Defendant was stopped after a police officer observed Defendant cross once and touch twice the fog line marking the outer right lane boundary on an interstate highway. Defendant was subsequently charged with alternative counts of driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the traffic stop of Defendant did not violate his constitutional rights because it was supported by reasonable suspicion. View "State v. Smith" on Justia Law

After a second jury trial, Defendant was convicted of thirty-seven counts of sexual battery by an authority figure. The Court of Criminal Appeals reversed the convictions and remanded for a new trial, holding that the State failed to make a proper election of offenses but that the evidence was sufficient to support the convictions. The Supreme Court reversed, holding (1) the election of offenses doctrine does not require the prosecution to identify a single incident of sexual battery in cases where the child victim testifies to repeated incidents of sexual contact occurring over a substantial period of time but does not furnish specific dates, details, or distinguishing characteristics as to individual incidents of sexual battery; (2) where a prosecution is based solely on generic evidence, such as this one, the trial court must provide the jury with a modified unanimity instruction that allows a conviction only if the jury unanimously agrees the defendant committed all the acts described by the victim; and (3) although the trial court did not provide such a modified unanimity instruction in this case, the omission of this instruction was harmless beyond a reasonable doubt. View "State v. Qualls" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err in admitting an autopsy report through the testimony of a medical examiner who did not perform the autopsy, as the autopsy report was not testimonial and therefore did not violate Defendant’s rights under the Confrontation Clause; (2) the warrantless search of Defendant’s home by officers who entered the home after the first responding officer’s initial entry into the home was lawful, and consequently, the trial court did not err by denying Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting items that were not in plain view, the error was harmless. View "State v. Hutchison" on Justia Law

Appellant filed a pro se motion under Tenn. R. Crim. P. 36.1 alleging that his sentences in two cases were illegal because the trial court increased his sentences above the statutory presumptive minimum sentence but failed to find enhancement factors justifying the increase. The Criminal Court denied Appellant’s Rule 36.1 motion, determining that Appellant’s sentences had expired and, therefore, the court had no jurisdiction to rule on Appellant’s Rule 36.1 motion. The Court of Criminal Appeals affirmed, concluding that Appellant had failed to state a colorable claim for relief under Rule 36.1. The Supreme Court affirmed, holding (1) the definition of “colorable claim” in Rule 28, section 2(H) of the Rules of the Tennessee Supreme Court applies to the term “colorable claim” in Rule 36.1; (2) the definition of “illegal sentence in Rule 36.1 is coextensive with the definition this Court has applied to the term for purposes of habeas corpus proceedings; and (3) in this case, Appellant failed to allege a colorable claim for correction of an illegal sentence. View "State v. Wooden" on Justia Law

Adrian Brown filed a pro se motion under Tenn. R. Crim. P. 36.1 seeking correction of allegedly illegal sentences imposed after he pleaded guilty to several crimes. The State responded that Brown’s Rule 36.1 motion should be dismissed because Brown’s sentences had expired. The trial court dismissed the motion without explanation. The Court of Criminal Appeals affirmed, holding that the expiration of Brown’s sentences rendered his Rule 36.1 motion moot. The Supreme Court affirmed, holding (1) Rule 36.1 does not authorize the correction of expired illegal sentences; and (2) the allegation that the trial court failed to award pretrial jail credits was not sufficient to state a colorable claim for relief from an illegal sentence under Rule 36.1. However, because Brown established a clerical error in the judgments on one of his convictions under Rule 36, the matter is remanded to the trial court for correction of the clerical error. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of rape of a child. During trial, when the prosecution made election of the facts it was relying upon to establish the charge, the prosecution mistakenly identified the method of sexual penetration. This error was repeated in the jury instruction concerning the election. Defendant appealed, challenging only the sufficiency of the evidence to support his conviction. The Court of Criminal Appeals affirmed. In affirming the conviction, the Court of Criminal Appeals sua sponte raised this issue of whether the error in the State’s election of offenses constituted reversible error. The court concluded that the State’s inaccurate election error was harmless. The Supreme Court affirmed, holding (1) the Court of Criminal Appeals erred by failing to subject the election issue to plain error analysis; but (2) after reviewing the record pursuant to the plain error doctrine, and under the circumstances of this case, the election error did not entitle Defendant to relief. View "State v. Knowles" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery of a store manager and four counts of especially aggravated kidnapping of four store employees. Defendant appealed, arguing that the trial court committed reversible error by failing to give a jury instruction based on the Supreme Court’s decision in State v. White. The Court of Criminal Appeals affirmed Defendant’s convictions, concluding that a White jury instruction was not required because the kidnapping and robbery charges did not involve the same victim. The Supreme Court affirmed, holding that a White jury instruction is not required when a defendant is charged with the kidnapping and robbery of separate victims. View "State v. Teats" on Justia Law

Defendant was tried on charges of kidnapping and robbery of a father, mother, and three children. At trial, a jury instruction based on the Supreme Court’s decision in State v. White was neither requested nor given. The jury convicted Defendant of five counts of especially aggravated kidnapping of the husband, wife, and three children; aggravated burglary of the husband’s residence; and two counts of aggravated robbery of the husband and wife. The Court of Criminal Appeals modified the conviction of aggravated robbery of the wife to aggravated assault and otherwise affirmed. The Supreme Court remanded the case for consideration in light of White. On remand, the Court of Criminal Appeals affirmed the convictions of especially aggravated kidnapping as to the three children but reversed the convictions of especially aggravated kidnapping as to the husband and wife and remanded those charges for a new trial . Defendant appealed the Court of Criminal Appeals’ holding that he was not entitled to a new trial for failure to receive a jury instruction as to the three kidnapping charges of the three children. The Supreme Court affirmed, holding that the White jury instruction was not required as to the offenses of especially aggravated kidnapping of the three children. View "State v. Williams" on Justia Law

Plaintiffs, five death-sentenced inmates, filed a declaratory judgment action against the Commissioner of the Tennessee Department of Correction (TDOC) and other TDOC officials challenging the constitutionality and legality of a 2014 statute that designated electrocution as an alternative method of execution and the constitutionality of electrocution as a means of execution. Defendants filed a motion to dismiss, arguing that Plaintiffs’ claims should be dismissed as unripe because the inmates were not currently subject to execution by electrocution and because the use of that method of execution in Tennessee was contingent on hypothetical, future, and speculative events. The trial court denied the motion, concluding that the claims were ripe because Plaintiffs were in danger of being electrocuted “in Tennessee’s electric chair.” The Supreme Court reversed and dismissed Plaintiffs’ electrocution claims as unripe, holding that because Plaintiffs were not currently subject to execution by electrocution and will not ever become subject to execution by electrocution unless one of two statutory contingencies occurs in the future, their claims challenging the constitutionality of the 2014 statute and electrocution as a means of execution are unripe and nonjusticiable. View "West v. Schofield" on Justia Law