Justia Civil Rights Opinion Summaries

Articles Posted in Tennessee Supreme Court
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The Supreme Court answered in the negative questions of law certified from the United States District Court for the Middle District of Tennessee regarding the constitutionality of Tennessee's statutory cap on noneconomic damages, Tenn. Code Ann. 29-30-102, holding that the statutory cap does not violate the right to trial by jury, the doctrine of separation of powers, or the equal protection provisions of the Tennessee Constitution. Specifically, the Supreme Court answered (1) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate a plaintiff’s right to a trial by jury, as guaranteed in Tenn. Const. art. I, 6; (2) the noneconomic damages cap in civil cases imposed by section 29-39-102 does violate Tennessee’s constitutional doctrine of separation of powers between the legislative branch and the judicial branch; and (3) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate the Tennessee Constitution by discriminating disproportionately against women. View "McClay v. Airport Management Services, LLC" on Justia Law

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The Supreme Court affirmed the court of criminal appeals' judgment affirming Defendant's conviction for one count of second degree murder, an alternative count of first degree felony murder, especially aggravated robbery, and three counts of aggravated assault, holding that, while the trial court erred in admitting certain testimony, substantial justice did not require that plain error relief be granted. At issue was whether the trial court committed reversible error in allowing the State to elicit testimony about a statement made by a non-testifying codefendant whose trial was severed and whose statements were the subject of a motion in limine granted by the trial court. After he was convicted, Defendant filed a motion for new trial, arguing that the trial court erred in concluding that the doctrine of curative admissibility permitted the testimony and, for the first time, raising a contention that the testimony violated his constitutional right of confrontation. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the testimony should not have been allowed, but Defendant was not entitled to plain error relief on his claim that the trial court violated his constitutional rights of confrontation by permitting the testimony; and (2) Defendant was not entitled to relief on the claims he preserved for plenary review. View "State v. Vance" on Justia Law

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The Supreme Court affirmed the judgment of the court of criminal appeals affirming Defendant's conviction for burglary, holding that application of the burglary statute under the circumstances of this case did not violate due process or prosecutorial discretion. Defendant's conviction arose from her involvement in a scheme to enter a Walmart retail store, steal merchandise, and have another individual return the merchandise for a gift card. Defendant had previously been banned from Walmart retail stores for prior acts of shoplifting, and the owners of these stores had issued documents to Defendant precluding Defendant from entering the stores. The State sought an indictment against Defendant for burglary rather than criminal trespass, reasoning that Defendant entered Walmart without the effective consent of the owner and committed a theft therein. Defendant appealed her burglary conviction, arguing that the burglary statute is unconstitutionally vague as applied to the extent that it implicates due process rights. The Supreme Court affirmed, holding (1) the language of the statute criminalizing burglary is clear and unambiguous on its face; (2) the statute is not unconstitutionally vague as applied, and nothing in the statute precludes its application to the fact scenario in this case; and (3) the prosecutor did not exceed her discretion in interpreting and applying the statute. View "State v. Welch" on Justia Law

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The Supreme Court reversed the decision of the court of criminal appeals affirming the judgment of the trial court granting Defendants' motion to suppress, holding that the warrantless search of a probationer's residence who is subject to a search condition does not require officers to have reasonable suspicion of illegal activity prior to conducting the search. Law enforcement conducted a warrantless search of the residence of a probationer and her husband, resulting in the discovery of illegal drugs and drug-related contraband. Pursuant to probation conditions imposed in a previous case, the probationer had agreed to a warrantless search of her person, property, or vehicle at any time. In affirming the trial court's decision to grant Defendants' motion to suppress, the court of criminal appeals concluded that the State was required to have reasonable suspicion to support the probation search and that the State lacked such suspicion in this case. The Supreme Court reversed, holding (1) because of the probation conditions to which the probationer was subject, the probation search of portions of the probationer's residence was constitutionally allowable; and (2) the search of probationer's husband's personal belongings located within Defendants' shared bedroom was proper pursuant to the doctrine of common authority. View "State v. Hamm" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence obtained from Defendant's computer pursuant to a search warrant, holding that Tenn. Code Ann. 39-17-1007 does not require search warrants to be applied for by the office of the district attorney general. A police officer applied for and obtained the search warrant, by which pornographic images of minors were recovered from Defendant's computer. In his motion to suppress, Defendant argued that suppression was warranted because the search warrant was not applied for by the district attorney general. The trial court denied the motion to suppress. Defendant subsequently pled guilty to one count of sexual exploitation of a minor. The court of appeals affirmed. The Supreme Court affirmed, holding that the search warrant and supporting affidavit were not required to comply with Tenn. Code Ann. 39-17-1007. View "State v. Miller" on Justia Law

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In this appeal from the grant of Defendant’s motion to suppress, the Supreme Court Court adopted the good-faith exception to the exclusionary rule set forth by the United States Supreme Court in Herring v. United States, 555 U.S. 135 (2009), but nevertheless affirmed the decision to suppress the evidence, holding that neither of Defendant’s arrests fell within the good-faith exception. A police officer arrested Defendant without a warrant because he was on a list of individuals who had been barred from housing authority property. Upon performing a search incident to arrest, the officer seized marijuana from Defendant. Almost three weeks later, the same officer again arrested Defendant on the same property based on the same list and again seized marijuana from Defendant. When it was discovered that the list was incorrect and that Defendant’s name should have been removed before he was arrested, the trial court suppressed the evidence in both cases. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) it is appropriate at this point to adopt the good-faith exception set forth in Herring; but (2) the facts of this case did not support application of the good-faith exception to the exclusionary rule. View "State v. McElrath" on Justia Law

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The Supreme Court affirmed Defendant’s convictions of the premeditated and felony murder of Clarence James and the premeditated and felony murder of Lillian James and Defendant’s sentences of death, holding that no reversible error occurred during the proceedings below. Specifically, the Court held (1) Defendant was not denied his constitutional right to counsel; (2) the trial court did not abuse its discretion in admitting into evidence certain testimony; (3) the evidence was sufficient to support Defendant’s convictions; (4) the trial court did not err in denying the appointment of a mitigation expert; and (5) Defendant’s death sentences were appropriate and not excessive or disproportionate to the penalty imposed in similar cases. View "State v. Jones" on Justia Law

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The Supreme Court affirmed the judgment of the Court of Criminal Appeals affirming the decision of the trial court to revoke Defendant’s judicial diversion for refusing to admit certain facts during his sex offender treatment, holding that Defendant’s due process rights were not violated because he was not specifically informed in conjunction with his nolo contendere plea that his judicial diversion could be revoked if he refused to admit certain facts during his sex offender treatment. Defendant pled nolo contendere to one count of solicitation of a minor and was placed on judicial diversion with a one-year probationary term. Defendant was required to register as a sex offender and to participate in sex offender treatment but was discharged from his treatment program for noncompliance. Thereafter, the trial court revoked Defendant’s diversion, adjudicated him guilty, and extended his probation. The Supreme Court affirmed, holding that due process does not require that a sex offender placed on judicial diversion with a probationary period to be informed specifically in conjunction with his plea that his judicial diversion and probation may be revoked if he is discharged from sex offender treatment due to his refusal to acknowledge that he committed the elements of the offense to which he pled. View "State v. Albright" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing death-sentenced inmates’ challenge to Tennessee’s current three-drug lethal injection protocol, holding that the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment under the Eighth Amendment to the United States Constitution or article I, section 16 of the Tennessee Constitution. This appeal was the third time the Supreme Court addressed the facial constitutionality of Tennessee’s lethal injection protocol. In the first two appeals the Court upheld the particular protocol in question. At issue in the instant appeal was Tennessee’s current three-drug protocol. The trial court dismissed the inmates’ complaint for declaratory judgment. The Supreme Court affirmed, holding (1) the inmates failed to establish that the three-drug protocol constitutes cruel and unusual punishment; and (2) the majority of the other issues raised by the inmates on appeal were rendered moot, and the inmates were not entitled to relief on their remaining issues. View "Abdur'Rahman v. Parker" on Justia Law

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The Supreme Court reversed the judgment of the trial court granting Defendant’s motion to suppress a blood sample drawn from Defendant pursuant to a search warrant because the arresting officer failed to leave a copy of the warrant with Defendant, holding that, under the facts and circumstances of this case, a good-faith exception should be applied to Tenn. R. Crim. P. 41’s exclusionary rule. The trial court granted Defendant’s motion to suppress the evidence obtained pursuant to the warrant on the basis of the exclusionary rule set out in Rule 41. The Court of Criminal Appeals affirmed. The Supreme Court reversed and remanded this matter to the trial court for further proceedings, holding that, given the specific facts of this case, a good-faith exception to Rule 41’s technical requirement that the officer executing a search warrant leave a copy of the warrant with the person searched should apply to this case. View "State v. Daniel" on Justia Law