Justia Tennessee Supreme Court Opinion Summaries

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

Defendant pleaded guilty to one count of possession of marijuana with intent to sell or deliver within 1,000 feet of a school zone, and other offenses. At the sentencing hearing, Defendant requested that the trial court place her on judicial diversion. The trial court denied Defendant’s request for judicial diversion, reasoning that there was a low likelihood that Defendant would be rehabilitated by judicial diversion. The Court of Appeals reversed the trial court’s denial of judicial diversion, concluding that the trial court failed to consider and weigh on the record all of the relevant factors in denying judicial diversion. The Supreme Court reinstated the trial court’s judgments, holding (1) the mandatory minimum service requirement of the Drug-Free School Zone Act does not render offenses under the Act ineligible for judicial diversion; and (2) although the trial court in this case failed adequately to address the appropriate factors on the record, Defendant’s request to be placed on judicial diversion was properly denied. View "State v. Dycus" on Justia Law

After a jury trial, Petitioner was convicted of first degree premeditated murder for fatally shooting his wife. After Petitioner’s conviction was affirmed in direct appeal, Petitioner filed a petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance by deciding not to consult an expert to rebut the anticipated testimony of a prosecution expert and by not attempting to introduce a potentially favorable hearsay statement. The post-conviction court denied the petition. The Court of Criminal Appeals reversed. The Supreme Court reversed, holding that Petitioner did not receive ineffective assistance from his trial counsel with regard to the issues before the Court on appeal. Remanded. View "Kendrick v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated burglary and other charges. The trial judge did not expressly accept or approve of the jury’s verdict. After Defendant’s trial and before the sentencing hearing, the trial judge left the bench and a successor judge was designated. The designated judge held a sentencing hearing, sentenced Defendant, and transferred the matter to a different division for further proceedings. Defendant moved for a new trial, alleging that a successor judge could not act as the thirteenth juror because witness credibility was the “over-riding issue.” A successor judge conducted the hearing on the motion. The trial court denied the motion. The Court of Criminal Appeals reversed on the thirteenth juror issue. The Supreme Court reversed the judgment of the Court of Criminal Appeals and reinstated the judgments of the trial court, holding that the successor judge in this correctly determined that he could perform the function of the thirteenth juror and could independently weigh and assess the evidence adduced at Defendant’s trial so as to prevent a miscarriage of justice by the jury. View "State v. Ellis" on Justia Law

Defendant was indicted for seven counts of rape of a child victim. Two weeks before trial, the State sought to offer as evidence a video recording of a statement made by the victim to a forensic interviewer pursuant to Tenn. Code Ann. 24-7-123. The trial court denied admission of the video recording, concluding (1) the enactment of section 24-7-123 intruded upon the inherent authority of the judiciary to regulate the admissibility of evidence; (2) the video-recorded statement qualified as hearsay evidence not admissible under any exception to the rule against the admission of hearsay evidence; and (3) the admission of the video recording would violate Defendant’s right to confront witnesses. The Court of Criminal Appeals denied the State’s request for an interlocutory appeal. The Supreme Court reversed, holding (1) section 24-7-123 does not unconstitutionally infringe upon the powers of the judiciary and is a valid legislative exception to the general rule against the admission of hearsay evidence; and (2) the admission of video-recorded statements does not violate a defendant’s right of confrontation so long as the child witness authenticates the video recording and appears for cross-examination at trial. View "State v. McCoy" on Justia Law