Justia Tennessee Supreme Court Opinion Summaries

Four university football players were indicted for criminal charges arising out of the alleged rape of a university student. Petitioners, a group of media organizations and a citizens group, made a Public Records Act request to inspect the police department’s files regarding its investigation of the football players. The police department denied the request. Petitioners filed a petition against the police department seeking access to the requested records under the Tennessee Public Records Act. The Court of Appeals concluded that all of the requested materials were relevant to a pending or contemplated criminal action and were therefore exempt from public disclosure under Tenn. R. Crim. P. 16. The Supreme Court affirmed on different grounds, holding (1) during the pendency of a criminal case and any collateral challenges to any conviction, Rule 16 governs the disclosure of information, and only the defendants, not the public, may receive information contained in the police investigative files; and (2) based on Rule 16, Petitioners have no right to the requested information during the pendency of the criminal cases and any collateral challenges to any convictions. View "The Tennessean v. Metro. Gov’t of Nashville & Davidson County" on Justia Law

After a jury trial, Petitioner was convicted of one count of aggravated burglary and multiple counts of aggravated rape, especially aggravated kidnapping, and aggravated robbery. The Court of Criminal Appeals affirmed. Petitioner then filed a petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court denied relief. The Court of Criminal Appeals reversed the post-conviction court’s judgment on Petitioner’s convictions for especially aggravated kidnapping but affirmed the judgment in all other respects, concluding that trial counsel was ineffective for failing to properly request jury instructions on aggravated kidnapping as a lesser-included offense of especially aggravated kidnapping. The Supreme Court affirmed in part and reversed in part, holding that the Court of Criminal Appeals (1) erred in concluding that Petitioner was prejudiced by his trial counsel’s failure to request a jury instruction on aggravated kidnapping; and (2) properly affirmed the denial of post-conviction relief on Petitioner’s other convictions. View "Moore v. State" on Justia Law

Plaintiff filed an action against Defendant within the extended statute of limitations set by a tolling agreement. Plaintiff voluntarily nonsuited the action and refiled it within one year but after the extended statute of limitations in the tolling agreement. The trial court granted summary judgment in favor of Defendant, determining that the case was not timely filed. The court of appeals affirmed, concluding that the tolling agreement precluded application of the savings statute and, therefore, Plaintiff’s claims were barred. The Supreme Court reversed, holding that, under the parties’ agreement, the savings statute applied to save the suit that Plaintiff refiled after the extended statute of limitations set in the tolling agreement but within the one-year period provided by the savings statute. Remanded. View "Circle C. Constr., LLC v. Nilsen" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the admission into evidence of an autopsy report through the testimony of a medical examiner who did not perform the autopsy was not testimonial, so its admission into evidence did not violate Defendant’s rights under the Confrontation Clause; (2) the responding officer’s initial entry into Defendant’s home was justified by exigent circumstances, and the subsequent entry into the home by other officers was a continuation of the responding officer’s entry into the home, and therefore, the trial court properly denied Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting into evidence items that were not in plain view during the warrantless search, the error was harmless. View "State v. Hutchison" on Justia Law

Defendant was stopped after a police officer observed him cross the double yellow center lane lines with the two left wheels of his car. Defendant was subsequently charged with driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the arresting officer’s seizure of Defendant did not violate Defendant’s constitutional rights, and therefore, the trial court did not err in denying Defendant’s motion to suppress. View "State v. Davis" on Justia Law

Defendant was stopped after a police officer observed Defendant cross once and touch twice the fog line marking the outer right lane boundary on an interstate highway. Defendant was subsequently charged with alternative counts of driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the traffic stop of Defendant did not violate his constitutional rights because it was supported by reasonable suspicion. View "State v. Smith" on Justia Law

After a second jury trial, Defendant was convicted of thirty-seven counts of sexual battery by an authority figure. The Court of Criminal Appeals reversed the convictions and remanded for a new trial, holding that the State failed to make a proper election of offenses but that the evidence was sufficient to support the convictions. The Supreme Court reversed, holding (1) the election of offenses doctrine does not require the prosecution to identify a single incident of sexual battery in cases where the child victim testifies to repeated incidents of sexual contact occurring over a substantial period of time but does not furnish specific dates, details, or distinguishing characteristics as to individual incidents of sexual battery; (2) where a prosecution is based solely on generic evidence, such as this one, the trial court must provide the jury with a modified unanimity instruction that allows a conviction only if the jury unanimously agrees the defendant committed all the acts described by the victim; and (3) although the trial court did not provide such a modified unanimity instruction in this case, the omission of this instruction was harmless beyond a reasonable doubt. View "State v. Qualls" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err in admitting an autopsy report through the testimony of a medical examiner who did not perform the autopsy, as the autopsy report was not testimonial and therefore did not violate Defendant’s rights under the Confrontation Clause; (2) the warrantless search of Defendant’s home by officers who entered the home after the first responding officer’s initial entry into the home was lawful, and consequently, the trial court did not err by denying Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting items that were not in plain view, the error was harmless. View "State v. Hutchison" on Justia Law

Plaintiff, a bank, filed suit against multiple defendants for fraud, constructive fraud, civil conspiracy, negligent misrepresentation, unjust enrichment, and violation of the Tennessee Securities Act. Three non-resident defendants (the “Ratings Agencies”) moved to dismiss based on lack of personal jurisdiction and failure to state a claim. The trial court granted the motion and dismissed Plaintiff’s claims. The Supreme Court (1) affirmed the judgment of the trial court finding that Plaintiff failed to establish a prima facie case of personal jurisdiction under a theory of general jurisdiction or specific jurisdiction; but (2) vacated the dismissal of Plaintiff’s action against the Ratings Agencies on the theory of conspiracy jurisdiction, holding that although Plaintiff has failed to establish a prima facie case of conspiracy jurisdiction at this point, the case must be remanded for the trial court to determine if Plaintiff should be allowed to conduct jurisdictional discovery on the conspiracy theory of personal jurisdiction in a manner consistent with the guidelines set forth in this opinion. View "First Cmty. Bank, N.A. v. First Tennessee Bank, N.A." on Justia Law

Mortgage Electronic Registration Systems, Inc. (MERS) brought this action to set aside a tax sale of real property, arguing that the county’s failure to provide it with notice of the sale violated his right to due process. The purchaser of the real property (Defendant) moved for judgment on the pleadings, asserting that MERS did not tender payment of the sale price plus the accrued taxes before bringing suit, as is statutorily required in a suit challenging the validity of a tax sale, and that MERS did not have a protected interest in the subject property. The trial court granted Defendant’s motion, concluding that MERS did not have an interest in the property. The Court of Appeals on the grounds that MERS lacked standing to file suit. The Supreme Court affirmed on different grounds, holding (1) MERS was not required to tender payment before filing this lawsuit; and (2) MERS acquired no protected interest in the subject property, and therefore, its due process rights were not violated by the county’s failure to notify it of the tax foreclosure proceedings or the tax sale. View "Mortgage Elec. Registration Sys., Inc. v. Ditto" on Justia Law