Justia Tennessee Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) the sentence of death was not excessive, disproportionate, or imposed arbitrarily; (3) the evidence was sufficient to support the jury's finding of the statutory aggravating circumstances beyond a reasonable doubt; and (4) the evidence supported the jury's finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt. View "State v. Pruitt" on Justia Law

The issue before the Supreme Court in this case centered on the appropriate response when a trial court learns during a jury's deliberations that a juror exchanged Facebook messages with one of the State's witnesses during the trial. The trial court declined the defendant's request to hold a hearing to question the juror and witness to ascertain whether the communications required a mistrial. The appellate court concluded that the trial court did no err in declining the request for a hearing. The Supreme Court disagreed, however, vacated the judgment and remanded the case for a hearing. View "Tennessee v. Smith" on Justia Law

The issue before the Supreme Court in this matter centered on whether the petitioner was entitled to seek post-conviction relief from a civil judgment that found her in criminal contempt and imposed sanctions. The Court held that a criminal contempt adjudication under Tennessee Code Annotated 29-9-102 (2012) does not amount to a criminal conviction under the general criminal laws for the purposed of the Post-Conviction Procedure Act. Accordingly, the Court affirmed the Court of Criminal Appeals, which affirmed dismissal of the petition. View "Baker v. Tennessee" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of false imprisonment and assault and sentenced to concurrent sentences of six months. While Defendant's case was pending on appeal, the Supreme Court filed its opinion in State v. White, which requires trial courts to provide a more specific instruction on kidnapping charges as to whether the removal or confinement of a victim is essentially incidental to any accompanying offense. On appeal, the court of appeals affirmed, holding that although the White instruction was not given at trial, the jury was correctly instructed and the evidence was sufficient to support both convictions. The Supreme Court reversed the conviction for false imprisonment, holding that the omission of the White instruction was not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Cecil" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law

Defendant was arrested on federal and state charges and taken into federal custody. After a trial in federal court, Defendant was convicted. Defendant was subsequently indicted by a Gibson County grand jury on the related state charges. After he was sentenced in federal court, Defendant was transported to Gibson County for an arraignment. Defendant was arraigned and then transferred back into federal custody. Defendant filed a motion to dismiss the state indictment for violations of the Interstate Agreement on Detainers (IAD), articles III and IV. Under article IV, an official of one jurisdiction may seek custody of a prison serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be shuttled back to the original place of imprisonment before the trial. The trial court denied the motion, and Defendant entered a conditional guilty plea. The court of criminal appeals affirmed the trial court's denial of Defendant's motion to dismiss. The Supreme Court reversed, vacated Defendant's conviction, and dismissed the indictment against Defendant with prejudice, holding that article IV of the IAD was violated when Defendant was transferred back to the federal detention center before being tried for the state charges. View "State v. Springer" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and tampering with physical evidence. The court of criminal appeals upheld Defendant's convictions and sentences. Defendant appealed, arguing (1) the trial court erred in declining his request for a jury instruction on defense of a third person, and (2) his abandonment of the murder weapon did not amount to tampering with physical evidence. The Supreme Court (1) affirmed Defendant's conviction for first degree murder, holding that the trial court properly denied Defendant's request for an instruction on defense of a third person; and (2) reversed Defendant's conviction for tampering with physical evidence, holding that Defendant did not "conceal" the murder weapon within the meaning of the relevant statute by tossing the murder weapon over a fence where it could be easily observed and recovered. View "State v. Hawkins" on Justia Law

Defendant pled guilty to reckless endangerment with a deadly weapon and theft of merchandise over five hundred dollars. The trial court sentenced Defendant as a Range II, multiple offender to three years on each count to be served concurrently. On appeal, Defendant argued that the trial court erred by failing to apply certain mitigating factors and by failing to grant probation or an alternative sentence. The court of criminal appeals, after declining to review the sentences because Defendant had failed to provide a transcript of the hearing on the guilty pleas, affirmed based upon a presumption that the evidence was sufficient to support the sentences. After granting an appeal because of conflicting opinions by the court of criminal appeals as to whether the absence of a transcript of a guilty plea submission hearing precludes appellate review on the merits, the Supreme Court ordered that the record be supplemented. The Court then affirmed the judgment of the trial court, holding that the record was adequate for a meaningful review of the sentences either with or without the transcript of the hearing on the guilty pleas, and Defendant was not entitled to relief. View "State v. Caudle" on Justia Law

The Supreme Court accepted this appeal to determined whether a lawyer's potential violation of the ethical rule governing communications with a person represented by another lawyer constitutes criminal contempt pursuant to Tenn. Code Ann. 29-9-102(1),(2). The trial court in this case convicted the attorney of criminal contempt. The attorney appealed, arguing that the evidence did not support the "misbehavior" element of criminal contempt pursuant to section 29-9-102(1). The court of criminal appeals found the evidence sufficient and upheld the conviction. The Supreme Court reversed the court of criminal appeals and vacated the attorney's conviction, holding that although a lawyer's violation of an ethical rule may in some circumstances amount to criminal contempt, the attorney's potential violation of the ethical rule governing communications with a person represented by another lawyer did not constitute criminal contempt pursuant to section 29-9-102(1),(2) because the evidence of "willful misbehavior" was insufficient to support his conviction beyond a reasonable doubt.View "State v. Beeler" on Justia Law