Justia Tennessee Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of attempted voluntary manslaughter, aggravated assault, and false imprisonment. Concluding that the separate convictions for attempted voluntary manslaughter and aggravated assault did not violate double jeopardy, the trial court declined to merge any of the convictions and imposed consecutive sentences totaling twenty-six years, eleven months, and twenty-nine days. The Court of Criminal Appeals affirmed the convictions and sentences. Defendant appealed, arguing that his sentences for attempted voluntary manslaughter and aggravated assault should be merged based upon the former double jeopardy principles set out in State v. Denton. The Supreme Court affirmed, holding (1) due process safeguards do not prohibit the retroactive application of the double jeopardy standard adopted in State v. Watkins, which was decided after the date of Defendant’s offenses; and (2) under Watkins, Defendant was not entitled to relief. View "State v. Feaster" on Justia Law

Defendants were indicted for aggravated robbery, aggravated burglary, and especially aggravated kidnapping. A jury convicted Defendants of all charges. The trial court set aside the guilty verdicts for especially aggravated kidnapping and aggravated burglary, concluding that these convictions, in conjunction with the aggravated robbery convictions, violated due process principles. The Court of Criminal Appeals reversed and reinstated the verdicts, finding that separate convictions for each of the offenses did not violate principles of due process or double jeopardy. The Supreme Court remanded to the intermediate appellate court for consideration in light of the Court’s holding in State v. Cecil, which applied the requirement of a jury instruction pursuant to State v. White to cases already in the appellate process on the date White was issued. On remand, the Court of Criminal Appeals reached the same result. The Supreme Court affirmed, holding (1) a kidnapping charge accompanied by an aggravated burglary charge does not, standing alone, warrant a White jury instruction; and (2) the trial court erred by not instructing the jury pursuant to the requirements of White with regard to the kidnapping charge as accompanied by the aggravated robbery charge, but the error was harmless. View "State v. Alston" on Justia Law

After a grand jury returned a presentment against Defendant for possession of marijuana, Defendant posted bond and was released. Thereafter, a grand jury issued a nineteen-count presentment against Defendant charging her with multiple crimes, including attempted first degree murder. The State moved to revoke Defendant’s bail. The trial court granted the motion pursuant to Tenn. Code Ann. 40-11-141(b). The Court of Criminal Appeals reversed, holding that section 40-11-141(b) violated Tenn. Const. art. I, 15. The Supreme Court remanded the case to the trial court for a bail revocation hearing, holding (1) a defendant has a constitutional right to pretrial release on bail; (2) however, this right is not absolute, and a defendant may forfeit his or her right to bail by subsequent criminal conduct; and (3) before pretrial bail can be revoked, the defendant is entitled to an evidentiary hearing. View "State v. Burgins" on Justia Law

After a jury trial, Defendant was convicted of one count of criminal attempt to commit sexual battery by an authority figure. Defendant appealed, arguing that the trial court erred by including criminal attempt to commit sexual battery by an authority figure in its jury instructions as a lesser-included offense of sexual battery by an authority figure. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err by including a jury instruction for criminal attempt as a lesser-included offense of sexual battery by an authority figure; and (2) the evidence at trial was sufficient for a jury to convict Defendant of criminal attempt to commit sexual battery by an authority figure. View "State v. Thorpe" on Justia Law