Justia Tennessee Supreme Court Opinion Summaries

In 2013, William Arnold was convicted in a criminal trial of one count of aggravated sexual battery and three counts of rape of a child for his rape and molestation of John Doe N. In 2011, the child’s mother, Ms. Bowen, filed a civil suit against Arnold, certain Boys and Girls Clubs and certain Big Brothers Big Sisters organizations, alleging that Arnold intentionally molested John Doe N and that the entity defendants were negligent. After the court of criminal appeals affirmed Arnold’s convictions, Bowen filed a motion for partial summary judgment against Arnold, arguing that Arnold was collaterally estopped from relitigating in the civil lawsuit the issue of whether he raped and sexually battered John Doe N. The trial court granted Bowen’s motion for partial summary judgment. The Supreme Court affirmed, holding (1) the Court hereby abolishes the mutuality requirement for defense and offensive collateral estoppel in Tennessee and adopts sections 29 and 85 of the Restatement (Second) of Judgments; and (2) applying section 85 of the Restatement (Second) of Judgments to the facts of this case, the trial court properly granted Bowen partial summary judgment against Arnold on the issue of whether he raped and sexually battered John Doe N. View "Bowen ex rel. Doe “N” v. Arnold" on Justia Law

In 2007, Landlord entered into a written agreement for the lease of commercial real estate to Tenant. In 2009, Landlord filed a complaint against Tenant and Richard Johnson alleging that Tenant breached the lease and that Johnson breached the personal guaranty agreement in the lease. The trial court dismissed Landlord’s claims against Johnson, concluding that Johnson was not personally liable for the obligations in the lease because he did not sign the lease in his personal capacity. At issue on appeal was whether Johnson agreed to be personally liable for Tenant’s obligations when he signed the agreement a second time. The Court of Appeals affirmed. The Supreme Court reversed, holding that Johnson’s second signature, “which followed a paragraph clearly indicating that the parties agreed that [Johnson] would be personally responsible for [Tenant’s] obligations,” was effective to bind Johnson. Remanded. View "MLG Enters., LLC v. Johnson" on Justia Law

Defendant was indicted for two counts of statutory rape and two counts of contributing to the delinquency of a minor. Defendant applied for pretrial diversion three times, and the district attorney general’s office denied her application each time. Defendant petitioned the trial court for a writ of certiorari after each denial, but the trial court denied each Petition. Upon interlocutory appeal of the trial court’s third denial, the Court of Criminal Appeals ruled in favor of Defendant and remanded with instructions to grant pretrial diversion, concluding that the record did not contain substantial evidence to support the denial of pretrial diversion. The Supreme Court reversed and reinstated the trial court’s judgment affirming the denial of pretrial diversion, holding that the district attorney general did not abuse his discretion in denying pretrial diversion and that the trial court properly found no abuse of discretion. View "State v. Stephens" on Justia Law

Defendant was indicted for assault. The district attorney general denied Defendant’s application for pretrial diversion, and the trial court refused to overturn the decision. The Court of Criminal Appeals granted Defendant’s interlocutory appeal, ruling (1) the trial court failed properly to review the district attorney general’s decision, and (2) there was a lack of substantial evidence supporting the denial of pretrial diversion. The Supreme Court vacated the judgment of the Court of Criminal Appeals and reinstated the trial court’s judgment, holding (1) the Court of Criminal Appeals erroneously reweighed the evidence and substituted its judgment for that of the district attorney general; and (2) although the trial court improperly reviewed the district attorney general’s action, the trial court reached the correct result. View "State v. Hamilton" on Justia Law

At issue in this case was the standard for determining whether a shareholder’s claim is a direct claim or a derivative claim. This case arose from a dispute among siblings who were shareholders in a closely-held family corporation. The conflict resulted in dissolution of the original family corporation, the formation of two new corporations, and a lawsuit. In the suit, one group of shareholder siblings asserted claims against the other group of shareholder siblings. The trial court awarded damages to the plaintiff shareholder siblings. The court of appeals reversed, concluding that the plaintiff shareholder siblings did not have standing because their claims were derivative in nature and belonged to their new corporation. The Supreme Court affirmed in part and reversed in part, holding (1) the traditional approach for determining whether a shareholder claim is direct or derivative described in Hadden v. City of Gatlinburg is hereby set aside; (2) the framework set forth by the Delaware Supreme Court in Tooley v. Donaldson, Lufkin & Jenrette, Inc. is hereby adopted; and (3) under the Tooley framework, the plaintiffs lacked standing to assert some claims but had standing as to other claims. View "Keller v. Estate of Edward Stephen McRedmond" on Justia Law

Petitioner pleaded guilty to second degree murder and was sentenced to twenty-five years in prison. Petitioner later filed this petition for writ of error coram nobis, claiming that he was entitled to a new trial on the basis of newly discovered evidence. The trial court denied the petition, and the Court of Criminal Appeals affirmed. At issue before the Supreme Court was whether a criminal defendant who pleads guilty may later seek to overturn his plea by way of a petition for writ of error coram nobis. The Supreme Court affirmed, holding (1) the Court’s holding in Wlodarz v. State that guilty pleas may be subject to a collateral attack via a petition for writ of error coram nobis is hereby overturned; and (2) the coram nobis statute is not available as a procedural mechanism for collaterally attacking a guilty plea. View "Frazier v. State" on Justia Law

Defendant was convicted of two counts of premeditated first-degree murder and one count of felony murder in the perpetration of a kidnapping. Defendant was sentenced to death on each conviction. The Court of Criminal Appeals upheld Defendant’s two convictions of first degree murder. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not violate Defendant’s right against self-incrimination or Defendant’s Sixth Amendment right to counsel by admitting into evidence certain incriminating statements Defendant made to his ex-wife; (2) the searches of Defendant’s home and storage unit did not violate the Fourth Amendment; (3) the trial court did not abuse its discretion in declining to exclude certain photographs of the victims and in denying Defendant’s ex parte motions for a crime scene expert and a false confession expert; (4) the sentences of death were not imposed in an arbitrary fashion and were neither excessive of disproportionate; and (5) the evidence supported the jury’s findings as to each first degree murder conviction. View "State v. Willis" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault committed by violating a protective order, and evading arrest. Defendant appealed, arguing that the trial court’s failure to compel the State to elect an offense as to the aggravated assault charge resulted in plain error. The Court of Criminal Appeals affirmed, concluding that, based upon the indictment and the State’s closing argument, Defendant’s right to a unanimous jury verdict was not violated. The Supreme Court affirmed Defendant’s conviction for evading arrest but reversed Defendant’s conviction for aggravated assault and remanded the matter for a new trial on that charge, holding that the failure to elect in this case was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

Defendant Christopher Davis was convicted of two counts of premeditated first degree murder, two counts of especially aggravated kidnapping, and two counts of especially aggravated robbery. The jury imposed death sentences for both counts of premeditated first degree murder after finding that evidence of three aggravating circumstances. In addition, the trial court sentenced the defendant to concurrent 25-year sentences for the especially aggravated kidnapping convictions to run consecutively to concurrent 25-year sentences for the especially aggravated robbery convictions. After the Court of Criminal Appeals affirmed the convictions and the sentences, the case was automatically docketed to the Supreme Court. Finding no reason to disturb the lower courts' judgments, the Supreme Court affirmed the conviction and sentences. View "Tennessee v. Davis" on Justia Law

In 1986, petitioner Torian Benson, a.k.a Marcus Terry, a.k.a Marcus Benson, pled guilty in to four counts of larceny and six counts of robbery, for which he was sentenced to three years imprisonment for each larceny count and five years for each robbery count. All sentences were ordered to be served concurrently, resulting in an effective sentence of five years. In 1989, petitioner entered guilty pleas to two counts of larceny and one count of aggravated assault, for which he was sentenced to three years for each count, all to be served concurrently, for an effective total sentence of three years. In 1993: petitioner entered a guilty plea to one count of theft of property over $10,000 and was sentenced to four years imprisonment; petitioner pled guilty to unlawful possession of a controlled substance with intent to sell and was sentenced to a term of eight years; and petitioner pled guilty to two counts of possession of a controlled substance and received an eight-year sentence for one count and a four-year sentence for the other. All of the 1993 convictions were ordered to be served concurrently. In 1997, petitioner was found guilty of two counts of vehicular homicide and sentenced to a term of fifteen years for each count. Based upon the petitioner’s prior convictions, the trial court found the petitioner to be a “career offender.” Under the sentencing guidelines, this designation required the court to impose the maximum sentence for felony offenses, which in the case of vehicular homicide was fifteen years. The trial court ordered both fifteen-year sentences to be served consecutively, not only with each other but also with another four-year sentence. In 2002, acting pro se, petitioner filed three separate petitions for writs of habeas corpus challenging the validity of the 1986, 1989 and 1993 convictions. The Court of Criminal Appeals affirmed the trial court’s denial of habeas corpus relief. Along with affirming the trial court’s initial findings, the intermediate court also held that habeas corpus relief was not available because the petitioner was not eligible for immediate release as he then-currently incarcerated on charges unrelated to those challenged in the petitions. Finding no reversible error as to the denial of habeas relief, the Tennessee Supreme Court affirmed. View "Benson v. Tennessee" on Justia Law