Justia Tennessee Supreme Court Opinion Summaries

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

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