Justia Tennessee Supreme Court Opinion Summaries

A confidential informant arranged a drug buy from a co-defendant. The co-defendant arrived in his truck with Defendant and another passenger. The three men were arrested, and a consensual search of the truck yielded 153 grams of cocaine and 8.6 grams of marijuana in close proximity to where Defendant had been seated. Police subsequently searched the co-defendant's residence, which yielded 293.5 grams of cocaine and drug paraphernalia. The State consolidated the weight of the cocaine and charged Defendant with possession with intent to sell 300 grams or more of cocaine, among other offenses. The jury convicted Defendant of possession with intent to sell 300 grams or more of cocaine and possession of drug paraphernalia. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a finding that Defendant constructively possessed the cocaine in the co-defendant's truck, but the evidence was insufficient to support a finding that Defendant constructively possessed the cocaine or drug paraphernalia in the co-defendant's residence; and (2) therefore, the cocaine conviction should be reduced to possession with intent to sell 26 to 299 grams of cocaine and the conviction for possession of drug paraphernalia should be vacated. Remanded for resentencing. View "State v. Robinson" on Justia Law

A grand jury returned an indictment charging Defendant with especially aggravated burglary, especially aggravated kidnapping, first degree premeditated murder, and first degree felony murder. That same day, the grand jury returned a superseding indictment re-charging Defendant and her husband with the same offenses but adding a charge of criminal conspiracy as to each. After Defendant's step-daughter testified before the grand jury, a second superseding indictment was issued charging all offenses in the first indictment and adding a charge of accessory after the fact against Defendant's husband. After a jury trial, Defendant was convicted of aggravated burglary, especially aggravated kidnapping, attempted first degree premeditated murder, and first degree felony murder. Defendant appealed, arguing that the trial court should have dismissed the charges because of prosecutorial abuse of the grand jury process. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the prosecutor acted improperly by compelling the testimony of Defendant's step-daughter in the grand jury proceeding, and the trial court properly denied Defendant's motions alleging prosecutorial abuse of the grand jury process. View "State v. Mangrum" on Justia Law

Defendant was charged with two counts of aggravated robbery and one count of especially aggravated kidnapping. The trial court subsequently granted Defendant's motion for a judgment of acquittal on the robbery charges. After a jury trial, Defendant was convicted of especially aggravated kidnapping. The court of criminal appeals affirmed the conviction. The Supreme Court affirmed, holding that the trial court did not err (1) by failing to inform the jury that Defendant had been acquitted of the robbery charges after those charges were dismissed; and (2) by failing to instruct the jury on accomplice testimony or by instructing the jury on criminal responsibility. View "State v. Little" on Justia Law

While on patrol, a police officer observed a pick-up truck parked in a shopping center lot. Because the truck's headlights were turned on, the officer stopped her patrol car directly behind the truck and activated her blue lights. The officer then approached the truck, observed a beer can in a cup holder inside, and found Defendant in the driver's seat with the keys in the ignition. Defendant was subsequently convicted for his fourth offense of driving under the influence. The court of criminal appeals reversed, holding (1) Defendant had been seized by the officer at the time the blue lights were activated; and (2) at the time of the seizure, the officer lacked either probable cause or reasonable suspicion to support an investigatory stop. The Supreme Court affirmed, holding (1) the activation of blue lights will not always qualify as a seizure; and (2) the totality of the circumstances in this instance established that the officer seized Defendant absent probable cause or reasonable suspicion and was not otherwise acting in a community caretaking role. View "State v. Moats" on Justia Law

After a jury trial, Petitioner was convicted of especially aggravated kidnapping, aggravated assault, especially aggravated robbery, and other robbery charges. The Supreme Court denied Petitioner's appeal, and the U.S. Supreme Court denied Petitioner's petition for writ of certiorari. Petitioner filed a petition for postconviction relief after the statutory deadline had passed because his former attorney provided him the wrong deadline date and failed to give Petitioner his legal files until after the actual deadline had passed. The criminal court dismissed the petition as untimely. The court of criminal appeals affirmed. The Supreme Court reversed and remanded the case to the trial court so Petitioner could pursue his petition for postconviction relief, holding (1) the facts of this case reflected that Petitioner was effectively abandoned by his appellate attorney after his petition for writ of certiorari was filed in the U.S. Supreme Court; (2) this abandonment impeded Petitioner's otherwise diligent efforts to file a timely postconviction petition; and (3) therefore, the statute of limitations should be tolled. View "Whitehead v. State" on Justia Law

Mother and Father entered into a martial dissolution agreement and parenting plan for their two minor children. Mother subsequently pleaded guilty to the attempted second degree murder of Father and was sentenced to twelve years incarceration. Mother and Father entered into an amended parenting plan that provided for the resumption of the original parenting plan after Mother's release from prison. Father remarried while Mother was incarcerated, and Father and Stepmother filed a petition for termination of Mother's parental rights and a petition for adoption by Stepmother. The trial court denied the petition after amending its original order, concluding that termination of Mother's parental rights was not in the best interests of the children. The court of appeals reinstated the trial court's original order terminating Mother's parental rights. The Supreme Court reversed the court of appeals and reinstated the amended order of the trial court, holding that Father and Stepmother failed to prove by clear and convincing evidence that termination of Mother's parental rights was in the best interests of the children. View "In re Taylor B.W." on Justia Law

Petitioner was convicted of premeditated first degree murder, especially aggravated robbery, and setting fire to person property. Petitioner subsequently filed a petition for post-conviction relief based partly on numerous instances of his trial counsel's ineffective assistance. The post-conviction court dismissed the petition. The court of criminal appeals, however, reversed Petitioner's convictions and remanded for a new trial, determining that Petitioner's trial counsel had been ineffective with regard to limitations placed on the ability of a defense expert to testify that Petitioner's mental condition rendered him unable to premeditate. The Supreme Court (1) reversed the judgment of the court of criminal appeals and affirmed the judgment of the post-conviction court on this issue, holding that Petitioner was not entitled to relief based on the manner in which his trial counsel dealt with the limitations placed of the defense's expert witness; and (2) reversed the judgment of the lower courts denying Defendant's claim relating to trial counsel's failure to object to the requirement that Petitioner wear a stun belt during the trial and remanded that issue for a new hearing, as the record did not permit the reviewing court to determine whether trial counsel was deficient with regard to this issue. View "Mobley v. State" on Justia Law

Defendant was convicted in three separate trials of three sets of execution-style murders, of seven persons total. Defendant faced seven death sentences. Defendant elected not to seek a new trial in any of these cases. Subsequently, Defendant's sister filed a "next friend" petition in each of the murder cases, requesting the courts to declare Defendant incompetent, thereby enabling her to pursue post-conviction relief on Defendant's behalf. Each court denied the petitions, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial courts employed the correct legal standard for determining whether Defendant possessed the mental capacity to rationally forego seeking post-conviction relief; (2) Defendant's sister failed to prove that Defendant lacked the capacity to make rational decisions regarding the pursuit of post-conviction relief; and (3) in all future cases, Tennessee's court should employ the mental competency standard of Tenn. Sup. Ct. R. 28, 11(B) to address the issue of a prisoner's competency to pursue post-conviction relief. View "Reid v. State" on Justia Law

Defendant was indicted on sixteen counts of animal cruelty for intentionally or knowingly failing to provide necessary food and care to horses on his farm. Defendant pleaded not guilty and filed an application for pretrial diversion, stating that he lacked a criminal history and claiming that the horses were sick when he received them. The assistant district attorney general denied the application, finding that the factors against granting pretrial diversion outweighed those in favor of granting pretrial diversion. Defendant filed a petition for writ of certiorari seeking judicial review. The trial court found no abuse of discretion, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding that the assistant district attorney general did not abuse his discretion in denying Defendant pretrial diversion. View "Stanton v. State" on Justia Law

Petitioner was sentenced to death in 1991 after pleading guilty to murder and rape. In 2010, Petitioner filed a petition seeking to reopen his post-conviction proceeding on the ground that he possessed new scientific evidence of his actual innocence. His evidence consisted of a newly-obtained I.Q. test score purporting to show he could not be executed because he was intellectually disabled. The trial court denied the petition, determining, as a matter of law, that Petitioner's I.Q. test score was not new scientific evidence of his actual innocence. The court of criminal appeals affirmed because the I.Q. test score did not amount to scientific evidence of actual innocence for the purpose of Tenn. Code Ann. 40-30-117(a)(2) and because Coleman v. State did not announce a new rule of constitutional law under section 40-30-117(a)(1). The Supreme Court affirmed, holding (1) the General Assembly, when it enacted section 40-30-117(a)(2), did not intend for the phrase "actually innocent of the offense" to include ineligibility for the death penalty because of intellectual disability; and (2) Coleman v. State does not establish a new rule of constitutional law that must be applied retroactively under section 40-30-117(a)(1). View "Keen v. State" on Justia Law