Articles Posted in Tennessee Supreme Court

by
In this case, the Supreme Court overruled State v. Jacumin, in which the Court rejected a totality-of-the circumstances analysis for determining whether an affidavit establishes probable cause and instead adopted another test derived from two earlier United States Supreme Court decisions. Defendant here was charged with multiple offenses in connection with a drug trafficking conspiracy. Defendant moved to suppress evidence seized during a search, arguing that the affidavit supporting the search warrant failed to establish probable cause. The trial court denied the motion. Defendant was then found guilty of six offenses. The Court of Criminal Appeals reversed the trial court’s ruling on Defendant’s motion to suppress. The Supreme Court reversed the intermediate appellate court’s decision holding that the search warrant was invalid, holding (1) henceforth, a totality-of-the-circumstances analysis applies for determining whether an affidavit establishes probable cause for issuance of a warrant, and applying this standard, the search warrant in this case sufficiently established probable cause; (2) the Court of Criminal Appeals erred in concluding that the evidence was insufficient to support two of Defendant’s convictions; and (3) the Court of Criminal Appeals did not err in upholding that trial court’s judgment ordering forfeiture of the $1,098,050 cash seized when the search warrant was executed. View "State v. Tuttle" on Justia Law

by
After a jury trial, Defendant was convicted of multiple counts of first degree murder, especially aggravated robbery, especially aggravated kidnapping, aggravated rape, and facilitation of aggravated rape. The Court of Criminal Appeals affirmed. The Supreme Court affirmed Defendant’s convictions and sentences of death, holding (1) Defendant’s claims of evidentiary error were without merit; (2) the trial court did not abuse its discretion by allowing the victims’ family members to wear buttons containing images of the victims; (3) the trial court properly effectuated merger of the convictions; (4) the sentences of death were not imposed in an arbitrary fashion; and (5) Defendant’s death sentences were neither excessive nor disproportionate to the penalty imposed in similar cases. View "State v. Davidson" on Justia Law

by
Defendant was charged with two counts of vehicular homicide and other crimes arising from a single-vehicle accident that killed two occupants of the vehicle. Defendant filed a motion to suppress any evidence derived from a blood sample obtained from her without a warrant the night of the accident. The trial court denied the motion to suppress, concluding that Defendant had orally consented to the blood draw. Defendant then filed a second motion to suppress. The trial court granted Defendant’s second motion to suppress, concluding that Defendant had not actually consented to the blood draw and that the police lacked reasonable grounds to believe Defendant was driving under the influence, which was required under the implied consent statute to justify the warrantless blood draw. The Court of Criminal Appeals reversed. The Supreme Court affirmed, holding that the police had probable cause to believe that Defendant was driving while intoxicated at the time of the accident, and thus, the implied consent statute was triggered. View "State v. Reynolds" on Justia Law

by
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

by
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

by
After a jury trial, Defendant was convicted of first offense driving under the influence. Defendant filed a motion for a new trial, arguing that the trial court erred by denying his motion to suppress on the grounds that the warrantless seizure of his parked vehicle and the ensuing field sobriety tests were not supported by reasonable suspicion. The trial court denied the motion. The Court of Criminal Appeals affirmed, concluding that the arresting officer’s activation of his patrol car’s rear blue lights was an exercise of the community caretaking function and not a seizure.The Supreme Court affirmed, holding (1) the Court’s decision in State v. Moats, which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements, was wrongly decided and is hearby overruled; (2) the community caretaking exception is an exception to the state and federal constitutional warrant requirements that may be invoked to validate as reasonable a warrantless seizure of an automobile; and (3) the community caretaking exception applies in this case. View "State v. McCormick" on Justia Law

by
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

by
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

by
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

by
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