Justia Tennessee Supreme Court Opinion Summaries

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

Appellant filed a pro se motion under Tenn. R. Crim. P. 36.1 alleging that his sentences in two cases were illegal because the trial court increased his sentences above the statutory presumptive minimum sentence but failed to find enhancement factors justifying the increase. The Criminal Court denied Appellant’s Rule 36.1 motion, determining that Appellant’s sentences had expired and, therefore, the court had no jurisdiction to rule on Appellant’s Rule 36.1 motion. The Court of Criminal Appeals affirmed, concluding that Appellant had failed to state a colorable claim for relief under Rule 36.1. The Supreme Court affirmed, holding (1) the definition of “colorable claim” in Rule 28, section 2(H) of the Rules of the Tennessee Supreme Court applies to the term “colorable claim” in Rule 36.1; (2) the definition of “illegal sentence in Rule 36.1 is coextensive with the definition this Court has applied to the term for purposes of habeas corpus proceedings; and (3) in this case, Appellant failed to allege a colorable claim for correction of an illegal sentence. View "State v. Wooden" on Justia Law

Adrian Brown filed a pro se motion under Tenn. R. Crim. P. 36.1 seeking correction of allegedly illegal sentences imposed after he pleaded guilty to several crimes. The State responded that Brown’s Rule 36.1 motion should be dismissed because Brown’s sentences had expired. The trial court dismissed the motion without explanation. The Court of Criminal Appeals affirmed, holding that the expiration of Brown’s sentences rendered his Rule 36.1 motion moot. The Supreme Court affirmed, holding (1) Rule 36.1 does not authorize the correction of expired illegal sentences; and (2) the allegation that the trial court failed to award pretrial jail credits was not sufficient to state a colorable claim for relief from an illegal sentence under Rule 36.1. However, because Brown established a clerical error in the judgments on one of his convictions under Rule 36, the matter is remanded to the trial court for correction of the clerical error. View "State v. Brown" on Justia Law

CBS Outdoor, Inc. applied to the Davidson County Metropolitan Department of Codes and Building Safety for two permits regarding billboards. The Zoning Administrator denied the permits. The Board of Zoning Appeals of Nashville and Davidson County, Tennessee (BZA) overturned the Zoning Administrator’s decision and granted the permits. The Metropolitan Government of Nashville and Davidson County, Tennessee (Metro) timely filed a petition for a writ of certiorari against the BZA in chancery court challenging the BZA’s order. The chancery court dismissed the petition, concluding that Metro did not have standing to bring this suit. The Court of Appeals reversed, holding that Metro had the requisite standing to bring this action. The Supreme Court affirmed, holding that the chancery court erred in dismissing the petition on the basis that Metro lacked standing. Remanded. View "Metro. Gov’t of Nashville & Davidson County, Tenn. v. Bd. of Zoning Appeals" on Justia Law