Justia Tennessee Supreme Court Opinion Summaries

In 2000, an affidavit of complaint was issued charging "John Doe" with an aggravated rape that occurred in 1994. The affidavit led to the issuance of an arrest warrant. In 2008, law enforcement officers discovered that fingerprints taken from the scene of the crime matched those of Defendant. Later, police determined that the DNA profile of "John Doe" contained in the affidavit was that of Defendant, and a superseding indictment was issued in his name. Defendant was subsequently convicted of attempted aggravated rape. Defendant appealed, arguing that the "John Doe" warrant with the DNA profile was insufficient to identify Defendant and commence prosecution within the applicable statute of limitations. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) a criminal prosecution is commenced if, within the statute of limitations for a particular offense, a warrant is issued identifying the defendant by gender and his or her unique DNA profile; and (2) furthermore, a superseding indictment in the defendant's name provides the requisite notice of the charge. View "State v. Burdick" on Justia Law

Defendant was found guilty of one count of facilitation of aggravated burglary and two counts of theft of property. After finding the presence of one enhancement factor, the trial court imposed concurrent three-year sentences for each offense. The court of criminal appeals found the enhancement factor did not apply and reduced each of the sentences to two years. The Supreme Court reversed the sentence modification by the court of criminal appeals and reinstated the sentence imposed by the trial court, holding (1) a sentence imposed by a trial court should be upheld so long as it is within the appropriate sentencing range and is otherwise in compliance with the purposes and principles of the sentencing statute; and (2) notwithstanding the trial court's reliance on an erroneous enhancement factor in this case, its imposition of three-year sentences was supported by the reasons articulated in the record. View "State v. Bise" on Justia Law

Defendant was sentenced following his conviction on two counts of first degree murder and nine counts of attempted first degree murder. Defendant's attorney subsequently filed a motion requesting a new trial and withdrew as counsel. The motion contained no specific grounds for relief. The trial court appointed replacement counsel. Several months later, replacement counsel amended the motion for new trial to allege specific grounds for relief. The trial court denied the amended motion for new trial. The court of criminal appeals held that the original motion for new trial was a nullity because it contained no grounds for relief and that the trial court therefore did not have jurisdiction to permit the amendment of the motion. The court of criminal appeals therefore considered Defendant's specific grounds for relief as waived. The Supreme Court reversed, holding that the original motion for new trial met the requirements of Tenn. R. Crim. P. 33 despite its failure to allege specific grounds for relief and that the trial court retained jurisdiction to permit the amendment of the motion. Remanded. View "State v. Lowe-Kelley" on Justia Law

An officer stopped Defendant for a traffic violation. When the officer ordered Defendant out of his vehicle to sign the citation, he observed what appeared to be a bag of cocaine on the floorboard of the driver's side. Charged with possession with intent to sell or deliver twenty-six grams or more of cocaine in a school zone, Defendant moved to suppress the evidence as the product of an unlawful seizure. The trial court sustained the motion, concluding that the request to exit the vehicle was not reasonably related to the stop. The court of criminal appeals affirmed. The Supreme Court reversed the order of suppression and remanded the cause for trial, holding than an officer, after making a lawful stop for a traffic violation, may routinely direct the driver outside of the vehicle. View "State v. Donaldson" on Justia Law

During a robbery, one of the defendants shot the victim in the leg. Although the bullet passed through the victim's leg, the wound required minimal medical treatment and did not cause the victim to suffer a loss of consciousness, extreme pain, disfigurement, or impairment. The defendants were convicted of especially aggravated robbery and aggravated robbery. The court of criminal appeals affirmed the convictions. The Supreme Court modified the convictions for especially aggravated robbery to convictions for aggravated robbery because the victim did not suffer a serious bodily injury as required by Tenn. Code Ann. 39-13-403. Remanded to the trial court for resentencing. View "State v. Farmer" on Justia Law

After an investigatory stop and frisk, Defendant was charged with the unlawful possession of a handgun after a felony conviction and the unlawful possession of a handgun while under the influence of alcohol and was convicted on both counts. Defendant appealed, arguing that his motion to suppress evidence should have been granted. The court of criminal appeals affirmed. The Supreme Court reversed the judgments of conviction and dismissed the cause, holding that because the investigatory stop and frisk of Defendant was not supported by specific and articulable facts establishing reasonable suspicion that a criminal act was being or about to be committed, the trial court erred by failing to suppress the handgun found by the police and presented as evidence at trial. View "State v. Williamson" on Justia Law

Defendant was tried and convicted of two counts of first degree murder and sentenced to death for each offense. The court of criminal appeals affirmed. The Supreme court affirmed in part and reversed in part, holding (1) the trial court erred by admitting detailed evidence of a prior claim of child sex abuse and by allowing references to Defendant's refusal to submit to a polygraph examination; (2) the prosecutor committed misconduct during the opening statement and during the final arguments of both the guilty and penalty phases of the trial; (3) however, the errors were harmless, and therefore, the convictions were affirmed; but (4) because certain of the inadmissible evidence was particularly inflammatory and the prosecution made several inappropriate comments, the sentences of death must be set aside. Remanded for new sentencing hearings. View "State v. Sexton" on Justia Law

At issue in this appeal was the procedure an inmate must follow to dispute the determination of parole eligibility when the inmate is serving consecutive determinate sentences imposed pursuant to the Criminal Sentencing Reform Act. Under the Uniform Administrative Procedures Act (UAPA), which governs an inmate's challenge to the Tennessee Department of Correction's (TDOC) calculation of a release eligibility date, an inmate must request a declaratory order from the TDOC before filing a declaratory action in court. Petitioner petitioned for a writ of certiorari naming the Board of Probation and Parole and TDOC. The trial court dismissed the petition. The Supreme Court affirmed the trial court, holding (1) because Petitioner failed to seek a declaratory order from TDOC, the trial court properly dismissed his petition naming TDOC and its officials; and (2) the UAPA does not govern an inmate's challenge to a decision of the Board concerning parole, and therefore, the trial court properly granted the Board's and its officials' motions to dismiss because the allegations of the petition failed to state a claim upon which relief could be granted. View "Stewart v. Schofield" on Justia Law

Father and Mother were jointly tried on two counts of felony murder and three counts of aggravated child abuse as a result of the death of their child. Only Mother testified in her own defense. During direct examination, Mother did not testify about prior incidents in which Father assaulted her. On cross-examination, Father's counsel asked Mother whether she believed Father was capable of hurting the victim. The trial court ruled sua sponte that counsel for Father had "opened the door" to cross-examination about Father's assaults against Mother. Father was subsequently convicted of felony murder and aggravated child abuse. Mother was convicted of facilitation of felony murder and aggravated child abuse. The Supreme Court reversed Mother's conviction, holding that the evidence of prior assaults by Father was inadmissible and that the parties did not open the door to cross-examination about Father's assaults against Mother. Remanded for a new trial. View "State v. Gomez" on Justia Law

More than fifteen years after Defendant's conviction for first degree murder became final, Defendant filed a petition for writ of error coram nobis alleging that he had recently discovered a note written by the assistant prosecutor before his murder trial expressing her opinion as to the lack of credibility of two of the State's witnesses. The petition alleged that the note was exculpatory, newly discovered evidence and that the State's failure to produce it before trial affected the outcome of the trial. The trial court tolled the one-year statute of limitations on due process grounds but summarily dismissed the petition. The court of criminal appeals reversed, concluding that the State had waived the statute of limitations defense and remanded for an evidentiary hearing. The Supreme Court reversed and reinstated the judgment of the trial court, holding (1) the State did not waive the statute of limitations defense, and the trial court did not err in tolling the statute of limitations; and (2) the handwritten note expressing the assistant prosecutor's opinion as to the witnesses' credibility was attorney work product, and as such, it was neither discoverable nor admissible. View "Wilson v. State" on Justia Law