Justia Tennessee Supreme Court Opinion Summaries

Defendant was indicted on four counts of theft. At trial, the trial court ruled that Defendant's prior misdemeanor convictions for passing worthless checks were admissible to impeach her credibility pursuant to Tenn. R. Evid. 609, which states that a conviction punishable by less than one year of imprisonment is admissible if the crimes involves dishonesty or false statement. Defendant elected not to testify, and the jury convicted her on three of the four counts of theft. The Supreme Court affirmed, holding that the crime of passing worthless checks involves an element of dishonesty or false statement and that the trial court did not abuse its discretion when it determined that Defendant's prior convictions could be used to impeach her credibility if she testified.View "State v. Russell" on Justia Law

An investor pursued a claim against an investment company over losses he incurred due to the failure of some of the company's bond funds. A Financial Industry Regulatory Authority arbitration panel ruled in the investor's favor. The investment company subsequently petitioned the chancery court to vacate the award based on the alleged bias of two members of the arbitration panel. The trial court vacated the award and remanded for a second arbitration before a new panel. The court of appeals dismissed the investor's appeal for lack of subject matter jurisdiction because the trial court's order did not expressly confirm or deny the arbitration award. The Supreme Court reversed, holding that the trial court's order was, in fact, an appealable order "denying confirmation" of an arbitration award under Tenn. Code Ann. 29-5-319(a)(3). Remanded. View "Morgan Keegan & Co. v. Smythe" on Justia Law

Employee fell while working for Employer and sustained a shoulder fracture. Employee subsequently filed a workers' compensation action. The trial court concluded that Employee had sustained a compensable injury during the course of her employment and awarded benefits to Employee. Employer appealed, arguing that Employee failed to carry her burden of proving the required causal connection between the employment conditions and the injuries she sustained as a result of her fall. Specifically, Employer contended that Employee's injuries resulted from an idiopathic fall and not from any hazard incident to her employment. The Supreme Court affirmed, holding that the evidence did not preponderate against the trial court's conclusion that Employee sustained a compensable injury arising out of her employment. View "Vandall v. Aurora Healthcare, LLC" on Justia Law

After injuring another student, a public high school student was cited for an infraction of the student conduct rule proscribing reckless endangerment. The principal's decision to suspend the student for ten days was upheld by a hearing board and the director of schools. Thereafter, the student and his family sought judicial review of the disciplinary decision. The trial court concluded (1) the school officials had violated the student's procedural due process rights because one official had performed both prosecutorial and decision-making functions and because this official was biased against the student; and (2) the evidence did not support the conclusion that the student's conduct amounted to reckless endangerment. Accordingly, the court directed the school system to expunge the student's record and awarded the student and his family attorneys' fees and costs. The court of appeals reversed. The Supreme Court affirmed, holding (1) the student received the required due process protections before he was suspended; (2) the hearing process after the student was suspended as applied did not render the proceedings fundamentally unfair; and (3) the court of appeals did not err by overturning the trial court's conclusion that the school officials acted arbitrarily and illegally.View "Heyne v. Metro. Nashville Bd. of Pub. Educ." on Justia Law

Defendant was charged with and convicted of first-degree premeditated murder and abuse of a corpse. On appeal, the court of criminal appeals modified Defendant's first degree murder conviction to second degree murder. The court also affirmed the trial court's denial of Defendant's motion to suppress. Defendant appealed, contending that the trial court erred in denying his motion to suppress his statements to the police on the grounds that they were elicited in violation of his constitutional right to counsel and were involuntary. The Supreme Court vacated Defendant's convictions, holding (1) Defendant's statements were erroneously admitted into evidence because Defendant did not invoke his constitutional right to counsel and did not waive his Miranda rights; (2) the physical evidence discovered as a result of Defendant's statements was properly admitted into evidence because the totality of the circumstances showed that Defendant's statements were voluntary and not coerced; and (3) the State failed to establish that the erroneous admission of Defendant's statements was harmless beyond a reasonable doubt. Remanded. View "State v. Climer" on Justia Law

After a jury trial, Defendant was convicted of premeditated first degree murder. During the penalty phase of the trial, Defendant refused to allow his lawyers to present mental health mitigation evidence. The trial court ruled that Defendant was competent to waive the presentation of expert mental health testimony. The jury sentenced Defendant to death. The court of criminal appeals affirmed Defendant's conviction and sentence. The Supreme Court affirmed, holding primarily that (1) a mentally competent defendant may waive the presentation of mitigation evidence during the penalty phase of a capital trial; (2) the trial court did not err in ruling that Defendant was mentally competent to waive the presentation of mitigation evidence; and (3) the death sentence in this case was not imposed in an arbitrary fashion and was not disproportionate to the penalty imposed in similar cases. View "State v. Johnson" on Justia Law

A confidential informant arranged a drug buy from a co-defendant. The co-defendant arrived in his truck with Defendant and another passenger. The three men were arrested, and a consensual search of the truck yielded 153 grams of cocaine and 8.6 grams of marijuana in close proximity to where Defendant had been seated. Police subsequently searched the co-defendant's residence, which yielded 293.5 grams of cocaine and drug paraphernalia. The State consolidated the weight of the cocaine and charged Defendant with possession with intent to sell 300 grams or more of cocaine, among other offenses. The jury convicted Defendant of possession with intent to sell 300 grams or more of cocaine and possession of drug paraphernalia. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a finding that Defendant constructively possessed the cocaine in the co-defendant's truck, but the evidence was insufficient to support a finding that Defendant constructively possessed the cocaine or drug paraphernalia in the co-defendant's residence; and (2) therefore, the cocaine conviction should be reduced to possession with intent to sell 26 to 299 grams of cocaine and the conviction for possession of drug paraphernalia should be vacated. Remanded for resentencing. View "State v. Robinson" on Justia Law

In a two-year period, more than eleven million cigarettes manufactured by an Indonesian cigarette manufacturer were sold in Tennessee. After the manufacturer withdrew its cigarettes from the United States market, the State suit the manufacturer, alleging that the manufacturer had failed to pay into the Tobacco Manufacturers' Escrow Fund as required by Tenn. Code Ann. 47-31-101 to -103. The trial court dismissed the suit for lack of personal jurisdiction over the manufacturer. The court of appeals reversed. At issue on appeal was whether Tennessee courts may exercise personal jurisdiction over the Indonesian manufacturer where the manufacturer's cigarettes were sold in the State through the marketing efforts of a Florida entrepreneur who purchased the cigarettes from an independent foreign distributor. The Supreme Court reversed, holding that Tennessee courts lacked personal jurisdiction over the manufacturer because the State failed to establish that the manufacturer purposely availed itself of the privilege of doing business in Tennessee. View "State v. NV Sumatra Tobacco Trading Co." on Justia Law

A grand jury returned an indictment charging Defendant with especially aggravated burglary, especially aggravated kidnapping, first degree premeditated murder, and first degree felony murder. That same day, the grand jury returned a superseding indictment re-charging Defendant and her husband with the same offenses but adding a charge of criminal conspiracy as to each. After Defendant's step-daughter testified before the grand jury, a second superseding indictment was issued charging all offenses in the first indictment and adding a charge of accessory after the fact against Defendant's husband. After a jury trial, Defendant was convicted of aggravated burglary, especially aggravated kidnapping, attempted first degree premeditated murder, and first degree felony murder. Defendant appealed, arguing that the trial court should have dismissed the charges because of prosecutorial abuse of the grand jury process. The court of criminal appeals affirmed. The Supreme Court affirmed, holding that Defendant failed to demonstrate that the prosecutor acted improperly by compelling the testimony of Defendant's step-daughter in the grand jury proceeding, and the trial court properly denied Defendant's motions alleging prosecutorial abuse of the grand jury process. View "State v. Mangrum" on Justia Law

Defendant was charged with two counts of aggravated robbery and one count of especially aggravated kidnapping. The trial court subsequently granted Defendant's motion for a judgment of acquittal on the robbery charges. After a jury trial, Defendant was convicted of especially aggravated kidnapping. The court of criminal appeals affirmed the conviction. The Supreme Court affirmed, holding that the trial court did not err (1) by failing to inform the jury that Defendant had been acquitted of the robbery charges after those charges were dismissed; and (2) by failing to instruct the jury on accomplice testimony or by instructing the jury on criminal responsibility. View "State v. Little" on Justia Law