Justia Tennessee Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to death. Defendant’s conviction and sentence were affirmed on appeal. Defendant subsequently filed a motion for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court concluded that Defendant was not entitled to a new trial on the murder conviction but was entitled to a new sentencing hearing based on ineffective assistance of counsel. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to prove by clear and convincing evidence a reasonable probability that, but for the deficient performance of his trial counsel, the verdict of guilt for first degree murder would have been different. Remanded for a new sentencing hearing. View "Nesbit v. State" on Justia Law

Defendant was indicted on six counts of aggravated sexual battery and four counts of rape of a child for sexually abusing his stepdaughter. Defendant moved to suppress a surreptitiously-recorded conversation with the child’s mother, who was secretly cooperating with the police in their investigation of the abuse. The trial court denied the motion to suppress. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that the admission of Defendant’s recorded conversation with the child's mother did not violate his constitutional right against compelled self-incrimination because, under the totality of the circumstances, Defendant’s incriminating statements were admissible because they were made voluntarily. View "State v. Sanders" on Justia Law

After a jury trial, Defendant was found guilty of seven counts of rape of a child and two counts of aggravated sexual battery arising from the sexual abuse of his children. The court of criminal appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions because the State presented adequate evidence corroborating Defendant’s confession to his wife; (2) the trial court properly refused to suppress surreptitiously-recorded conversations between Defendant and his wife; (3) the trial court erred by admitting evidence that Defendant possessed and viewed adult pornography, but the error was harmless; and (4) any error in jury instructions given during trial that the mental state of “recklessness” could support a conviction for aggravated sexual battery was harmless beyond a reasonable doubt. View "State v. Clark" on Justia Law

After a jury trial, Defendant was convicted of aggravated burglary and employment of a firearm during the commission of a dangerous felony. Defendant appealed, arguing that the trial court (1) erred by denying his request for a special jury instruction on the definition of actual and constructive possession as an element of employment of a firearm, and (2) erred by failing to instruct the jury on the crime of possession of a firearm during the commission of a dangerous felony as a lesser included offense. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err by refusing Defendant’s request for a special instruction on the definition of possession; and (2) possession of a firearm during the commission of a dangerous felony qualifies as a lesser included offense of employment of a firearm during the commission of a dangerous felony, but Defendant waived the issue and was not entitled to relief under the plain error doctrine. View "State v. Fayne" on Justia Law

A Shelby County grand jury indicted Defendant for two counts of first degree premeditated murder and two counts of first degree murder for the murders of Lillian and Clarence James. During trial, the court admitted evidence of a third murder allegedly committed by Defendant in another state, concluding that the out-of-state murder constituted a signature crime and was relevant to the issue of identity. The jury returned verdicts of guilt for the felony murder and the premeditated murder of the two victims. The court of criminal appeals affirmed. The Supreme Court reversed the convictions, holding (1) the trial court erred by allowing the proof of the out-of-state murder, as the similarities involved in that murder did rise to the level of a signature crime, and, under the circumstances, the danger of unfair prejudice outweighed the probative value of the evidence; and (2) the error was not harmless. Remanded for a new trial. View "State v. Jones" on Justia Law

Defendant was convicted of multiple counts of especially aggravated sexual exploitation of a minor, criminal exposure of another to HIV, and aggravated statutory rape. The trial judge sentenced Defendant to an effective sentence of 174 years. The court of criminal appeals affirmed. The Supreme Court affirmed all eleven convictions of especially aggravated sexual exploitation of a minor, all six convictions of aggravated statutory rape, and four of the seven convictions for criminal exposure of another to HIV, holding (1) there was sufficient evidence to support the separate convictions of especially aggravated sexual exploitation of a minor and aggravated statutory rape; (2) there was sufficient evidence to support the convictions for four counts of criminal exposure to HIV but insufficient evidence to support the convictions for three of the counts; and (3) Defendant’s sentence, as modified, was not excessive. View "State v. Hogg" on Justia Law

Sandy Womack was convicted and sentenced to a term of confinement with the Tennessee Department of Correction (TDOC). While Womack was housed at the Whiteville Correctional Facility in Hardman County, which was owned and operated by Corrections Corporation of America (CAA), a private entity, Womack filed suit against CAA in the Circuit Court for Davidson County, alleging that CAA had negligently failed to address his medical needs. CAA moved to dismiss the complaint or to transfer it to Hardeman County in accordance with Tenn. Code Ann. 41-21-803, asserting that section 41-21-803 “effectively localized actions brought by prisoners.” The Davidson County court granted the motion and transferred the case to Hardeman County. The court of appeals affirmed. The Supreme Court reversed, holding that section 41-21-803 did not apply to Womack’s lawsuit because his cause of action accrued while he was housed in the privately operated Whiteville Correctional Facility rather than in a facility operated by the TDOC within the meaning of the statute. View "Womack v. Corr. Corp. of Am." on Justia Law

Defendant was convicted of first degree premeditated murder, first degree felony murder, and related offenses. The trial court imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the court of criminal appeals did not err by affirming the trial court’s denial of Defendant’s motion to suppress statements he gave to law enforcement officers on the basis that the confessions were knowingly and voluntarily made; and (2) Defendant’s death sentence was not imposed arbitrarily, the evidence supported the trial court’s finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt, and the sentence of death was not disporportionate. Remanded for entry of a corrected judgment reflecting the trial court’s merger of Defendant’s convictions for first degree murder into a single conviction. View "State v. Freeland" on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of criminal appeals affirmed. The Supreme Court vacated Defendant’s conviction and sentence, holding (1) the lead prosecutor violated Defendant’s constitutional right against self-incrimination during final closing argument by making a remark that the jury necessarily would have taken to be a comment on Defendant’s exercise of her constitutional right not to testify; (2) the prosecution violated Defendant’s constitutional right to due process by failing to provide to the defense until after the trial the third statement a key witness gave to law enforcement officers investigating the murder; and (3) these constitutional errors were not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Jackson" on Justia Law