Justia Tennessee Supreme Court Opinion Summaries

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

After a jury trial, Defendant was found guilty of two counts of aggravated sexual battery. The Court of Appeals affirmed Defendant’s conviction and sentence, holding (1) the trial court erred by deviating from the requirements of Tenn. R. Crim. P. 24 during the jury selection process, but that error neither interfered with Defendant’s ability to fully exercise his peremptory challenges nor prejudiced him; and (2) Defendant’s remaining issues were without merit. The Supreme Court vacated Defendant’s conviction, holding (1) the evidence was sufficient to support Defendant’s conviction of aggravated sexual battery; but (2) the trial court’s deviations from the prescribed jury selection procedures in Rule 24 prejudiced the judicial process, and therefore, this matter must be remanded for a new trial. View "State v. Frausto" on Justia Law

Defendant was indicted for driving under the influence and violating the open container law. Defendant moved to suppress all evidence discovered during the search of her car. The trial court granted the motion to suppress, concluding that one of the officers who, in response to a dispatch, had detained Defendant unlawfully prolonged the investigatory stop. The Court of Criminal Appeals affirmed. The Supreme Court set aside the order of suppression, holding that the officer had a reasonable basis for extending the stop by ten to fifteen minutes while awaiting the arrival of a second officer, and the duration of the investigatory detention did not exceed the “proper parameters.” Remanded. View "State v. Montgomery" on Justia Law

Defendant was convicted of rape of a child and sentenced to twenty-five years' imprisonment. The Court of Criminal Appeals affirmed, holding (1) the trial court erred by allowing the prosecution to introduce the child victim’s prior consistent statement before the child’s credibility had been challenged and by ruling that if Defendant chose to testify the prosecution would be allowed to ask him whether he had previously been arrested or convicted of a felony, but (2) these errors were neither individually nor cumulatively prejudicial. The Supreme Court reversed and remanded for a new trial, holding that the cumulative effect of the two trial errors was prejudicial and entitled Defendant to a new trial. View "State v. Herron" on Justia Law

Defendant was convicted of two counts of felony murder in the perpetration of a first degree burglary and other crimes. The jury sentenced Defendant to death for the murder of one victim and to life imprisonment for the murder of the second victim. The Court of Criminal Appeals and Supreme Court affirmed on appeal. Defendant subsequently field a petition for post-conviction relief, alleging that he received ineffective assistance of counsel. On review, the Supreme Court granted Defendant a delayed appeal based upon the lack of meaningful representation during the original direct appeal. Upon remand, Defendant moved for a new trial and an accompanying petition for writ of error coram nobis. The circuit court denied relief as to all claims. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding (1) Defendant failed to establish that witness credibility was such an overriding issue that the trial judge was unable to consider the motions for new trial; (2) Defendant was not entitled to a new trial based upon “newly discovered evidence”; (3) the use of shackles in this instance was appropriate; and (4) the evidence at trial was sufficient to support Defendant’s convictions. View "State v. Hall" on Justia Law

After law enforcement officers discovered child pornography on Defendant’s home computer, Appellant was found guilty of felony sexual exploitation of a minor by knowingly possessing over 100 images of child pornography. The State then filed a complaint for judicial forfeiture against Appellant. Because foreclosure proceedings were already underway, the trial court enjoined the mortgage lender from disbursing to Appellant any excess proceeds from the anticipated foreclosure sale. After Appellant’s home was sold at auction and a trial was held on the complaint for forfeiture, the trial court ordered forfeiture of the proceeds from the sale of Appellant’s home. The court of appeals affirmed. The Supreme Court reversed, holding (1) in forfeiture proceedings, the seizing authority is required to present affirmative proof that it complied with both the procedural and the substantive requirements in the forfeiture statutes; (2) both the procedural and the substantive provisions of the forfeiture statutes must be strictly construed; and (3) the State in this case failed to show that it complied with the procedural requirements in the forfeiture statutes. View "State v. Sprunger" on Justia Law

Defendant’s minor daughter was diagnosed with a rare form of cancer and died at the age of fifteen. Defendant was indicted for neglect of a child under the age of eighteen based on her failure to obtain adequate medical treatment for her daughter. Defendant moved to dismiss the charge, arguing that the “spiritual treatment” exemption within the child abuse and neglect statute, which precludes the prosecution of parents who, under certain circumstances, provide treatment through prayer alone in lieu of medical treatment, is unconstitutional. The trial court rejected Defendant’s constitutional claims and denied her motion to dismiss. After a trial, the trial court concluded that Defendant did not qualify for the spiritual treatment exemption and found her guilty of child neglect. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the spiritual treatment exemption is not unconstitutionally vague; and (2) because the exemption may be elided without invalidating the remainder of the child abuse and neglect statute, Defendant’s remaining constitutional challenges would not afford relief. View "State v. Crank" on Justia Law