Justia Tennessee Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to life imprisonment. The court of criminal appeals affirmed the conviction and sentence but granted permission to appeal to address whether a discharged alternate juror's communication to the jury foreman entitled Defendant to a new trial. The Supreme Court affirmed, holding (1) the State presented sufficient, admissible evidence to rebut the presumption of prejudice that accompanies an improper outside influence upon the jury, and because there was no reasonable possibility that the note from the discharged alternate juror to the foreman affected the verdict, Defendant was not entitled to relief on this issue; (2) the trial court did not err with respect to the admission of evidence or its jury instructions; and (3) the evidence was sufficient to convict Defendant of first degree premeditated murder. View "State v. Adams" on Justia Law

After a jury trial, Defendant was convicted of especially aggravated robbery and felony murder. Defendant appealed, asserting that the evidence was insufficient to support his convictions. The court of criminal appeals found the evidence was insufficient to support the defendant's conviction of especially aggravated robbery and remanded to the trial court for re-sentencing on Defendant's conviction of second degree murder. The State appealed. The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court, holding that the evidence was sufficient to support Defendant's convictions of especially aggravated robbery and felony murder.View "State v. Wagner" on Justia Law

Defendant, convicted of felony murder and sentenced to life in prison, appealed, alleging a number of errors in the conduct of the trial, particularly the trial court's failure to suppress a statement Defendant had made to the police. The court of criminal appeals held that the admission of the statement qualified as harmless error. The Supreme Court granted Defendant's application for permission to appeal in order to determine the propriety of Defendant's arrest and to consider whether the court of criminal appeals had used the appropriate standard of review in its harmless error analysis. The Supreme Court then affirmed the judgment, holding that the arrest of Defendant was supported by probable cause and there was no other prejudicial error during the course of the trial.View "State v. Echols" on Justia Law

Defendant was indicted on four counts of theft. At trial, the trial court ruled that Defendant's prior misdemeanor convictions for passing worthless checks were admissible to impeach her credibility pursuant to Tenn. R. Evid. 609, which states that a conviction punishable by less than one year of imprisonment is admissible if the crimes involves dishonesty or false statement. Defendant elected not to testify, and the jury convicted her on three of the four counts of theft. The Supreme Court affirmed, holding that the crime of passing worthless checks involves an element of dishonesty or false statement and that the trial court did not abuse its discretion when it determined that Defendant's prior convictions could be used to impeach her credibility if she testified.View "State v. Russell" on Justia Law

After a jury trial, Defendant was convicted of premeditated first degree murder. During the penalty phase of the trial, Defendant refused to allow his lawyers to present mental health mitigation evidence. The trial court ruled that Defendant was competent to waive the presentation of expert mental health testimony. The jury sentenced Defendant to death. The court of criminal appeals affirmed Defendant's conviction and sentence. The Supreme Court affirmed, holding primarily that (1) a mentally competent defendant may waive the presentation of mitigation evidence during the penalty phase of a capital trial; (2) the trial court did not err in ruling that Defendant was mentally competent to waive the presentation of mitigation evidence; and (3) the death sentence in this case was not imposed in an arbitrary fashion and was not disproportionate to the penalty imposed in similar cases. View "State v. Johnson" on Justia Law

Defendant was charged with and convicted of first-degree premeditated murder and abuse of a corpse. On appeal, the court of criminal appeals modified Defendant's first degree murder conviction to second degree murder. The court also affirmed the trial court's denial of Defendant's motion to suppress. Defendant appealed, contending that the trial court erred in denying his motion to suppress his statements to the police on the grounds that they were elicited in violation of his constitutional right to counsel and were involuntary. The Supreme Court vacated Defendant's convictions, holding (1) Defendant's statements were erroneously admitted into evidence because Defendant did not invoke his constitutional right to counsel and did not waive his Miranda rights; (2) the physical evidence discovered as a result of Defendant's statements was properly admitted into evidence because the totality of the circumstances showed that Defendant's statements were voluntary and not coerced; and (3) the State failed to establish that the erroneous admission of Defendant's statements was harmless beyond a reasonable doubt. Remanded. View "State v. Climer" on Justia Law