Justia Tennessee Supreme Court Opinion Summaries

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

Defendant Delawrence Williams was indicted for possession of over one-half gram of cocaine with the intent to sell or deliver. He filed a motion to suppress the evidence, arguing that probable cause had not been shown for the issuance of a search warrant. The Court of Criminal Appeals affirmed the trial court’s decision to deny the motion to suppress. The Supreme Court granted this interlocutory appeal to review: (1) whether the information used to obtain a search warrant to search the defendant’s residence was provided by a “citizen informant” and presumptively reliable; and (2) whether the information, if not provided by a “citizen informant,” nonetheless established probable cause under "Tennessee v. Jacumin," (778 S.W.2d 430 (Tenn. 1989)). After reviewing the record and applicable authority, the Supreme Court held: (1) that the trial court and the Court of Criminal Appeals properly granted the interlocutory appeal pursuant to Rule 9 of the Tennessee Rules of Appellate Procedure; and (2) that although the information used to obtain the search warrant for the defendant’s residence was not provided by a “citizen informant,” it established probable cause under the two-prong analysis in Jacumin. The judgment was therefore affirmed. View "Tennessee v. Williams" on Justia Law

Cracker Barrel Old Country Store, Inc., and Cracker Barrel Associates, LLC, (collectively “Plaintiffs”) owned certain real property on Sidco Drive in Davidson County. Richard Epperson and Timothy Causey (collectively “Defendants”) owned adjoining property. Both parcels were subject to a Declaration of Reciprocal Rights and Easements and Restrictive Covenants (“Declaration”), created by the original developer of these two parcels and several others in the same development. In April 2005, Defendants submitted to the Nashville/Davidson County Metropolitan Council a proposal to expand the building on their property. Upon learning of the plan, Plaintiffs notified Defendants that they believed the new construction would violate covenants 1(a), 2, and 3 of the Declaration, granting mutual vehicular easements to the adjoining owners and prohibiting obstruction to traffic flow. Defendants disagreed and persisted in seeking approval for their plan. In August, Plaintiffs filed suit to try and stop Defendants' building plans. The trial court ultimately granted Plaintiffs’ motion for temporary injunctive relief. On October 21, 2005, Plaintiffs filed a Motion for Costs and Expenses, seeking almost $62,000 in attorney fees to that point. The ultimately resolved the substantive issues of the lawsuit and on January 30, 2006, the trial court entered an Agreed Judgment and Permanent Injunction, which permanently enjoined Defendants from expanding the building on their property. With regard to fees, the parties agreed that they would submit the fee matter to non-binding mediation. After the parties failed to reach an agreement, Plaintiffs renewed their motion for costs and expenses, requesting $3,913.75 in costs and expenses and a total of $117,334.50 in attorney fees. In their response to Plaintiffs’ motion, Defendants again asserted that Plaintiffs were not entitled to recover attorney fees because the Declaration did not expressly provide for their recovery. The trial court ultimately denied Plaintiffs’ request for attorney fees, explaining that no authority presented supported a finding that the contractual language of Paragraph 9 of the Declaration created a right to recover attorney fees. On appeal, the Court of Appeals affirmed the trial court’s denial of attorney fees. The Tennessee Supreme Court granted Plaintiffs’ application for review to clarify the application of the American rule regarding attorney fees to the language in the Declaration, and affirmed the Court of Appeals. View "Cracker Barrel Old Country Store, Inc., et al. v. Epperson, et al." on Justia Law

After its closure, a landfill continued to discharge contaminants into a creek that ran into a lake on adjoining property. After several failed remedial measures, ACC, LLC (ACC), the landfill owner, and the Tennessee Department of Environment and Conservation agreed to a plan to abate the discharge. The plan required ACC to divert water from entering the landfill and, within a four-year period, to remove and relocate the landfill waste. StarLink Logistics, Inc., the landowner of the property on which the lake was located, objected to the plan. The Tennessee Solid Waste Disposal Control Board approved ACC’s plan of action. The trial court affirmed. The Court of Appeals rejected the Board’s decision and remanded the case to the Board to explore more options. The Supreme Court reversed, holding that the Court of Appeals misapplied the arbitrary and capricious standard and instead substituted its judgment for that of the Board. Remanded. View "Starlink Logistics, Inc. v. ACC, LLC" on Justia Law

After a jury trial, Defendant was convicted of first offense driving under the influence. Defendant filed a motion for a new trial, arguing that the trial court erred by denying his motion to suppress on the grounds that the warrantless seizure of his parked vehicle and the ensuing field sobriety tests were not supported by reasonable suspicion. The trial court denied the motion. The Court of Criminal Appeals affirmed, concluding that the arresting officer’s activation of his patrol car’s rear blue lights was an exercise of the community caretaking function and not a seizure.The Supreme Court affirmed, holding (1) the Court’s decision in State v. Moats, which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements, was wrongly decided and is hearby overruled; (2) the community caretaking exception is an exception to the state and federal constitutional warrant requirements that may be invoked to validate as reasonable a warrantless seizure of an automobile; and (3) the community caretaking exception applies in this case. View "State v. McCormick" on Justia Law

American Heritage Apartments, Inc., a customer of the Hamilton County Water and Wastewater Treatment Authority (County Authority), filed suit both individually and as a class representative asserting that the County Authority exceeded its statutory authority by imposing a monthly charge on its customers. The County Authority sought dismissal of the lawsuit for failure to exhaust administrative remedies, arguing that a customer who seeks to dispute the rates charged must first follow the administrative procedures provided in the Utility District Law of 1937 (UDL). The trial court agreed and dismissed the lawsuit. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the administrative procedures in Part 4 of the UDL do not apply to a rate challenge filed by an individual customer against a water and wastewater treatment authority, and therefore, the trial court erred in dismissing the lawsuit for failure to exhaust administrative remedies; and (2) the trial court’s alternative ruling on class certification is vacated, and that issue is remanded to the trial court for reconsideration. View "Am. Heritage Apartments, Inc. v. Hamilton County Water & Wastewater Treatment Auth." on Justia Law

American Heritage Apartments, Inc., a customer of the Hamilton County Water and Wastewater Treatment Authority (County Authority), filed suit both individually and as a class representative asserting that the County Authority exceeded its statutory authority by imposing a monthly charge on its customers. The County Authority sought dismissal of the lawsuit for failure to exhaust administrative remedies, arguing that a customer who seeks to dispute the rates charged must first follow the administrative procedures provided in the Utility District Law of 1937 (UDL). The trial court agreed and dismissed the lawsuit. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) the administrative procedures in Part 4 of the UDL do not apply to a rate challenge filed by an individual customer against a water and wastewater treatment authority, and therefore, the trial court erred in dismissing the lawsuit for failure to exhaust administrative remedies; and (2) the trial court’s alternative ruling on class certification is vacated, and that issue is remanded to the trial court for reconsideration. View "Am. Heritage Apartments, Inc. v. Hamilton County Water & Wastewater Treatment Auth." on Justia Law

In 1998, Petitioner was convicted of two counts of first-degree murder and sentenced to death. Petitioner subsequently pursued collateral review without success. In 1990, the Tennessee General Assembly passed legislation providing that no defendant with an intellectual disability at the time of committing first-degree murder shall be sentenced to death. In 2012, Petitioner filed a motion to reopen his petition for postconviction relief, arguing that he was intellectually disabled within the meaning of the intellectual disability statute. Thereafter, the Supreme Court issued its decision in Keen v. State, in which the Court held that Coleman v. State did not provide a basis for reopening a postconviction proceeding in order to assess a capital defendant’s claim of intellectual disability. Petitioner subsequently filed an amended petition for relief from death sentences seeking relief pursuant to the error coram nobis statute and the intellectual disability statute. The trial court denied the motion to reopen and amended petition without holding an evidentiary hearing. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding that the procedural avenues by which Petitioner was seeking relief in this proceeding did not entitle him to the hearing he sought. View "Payne v. State" on Justia Law