Justia Civil Rights Opinion Summaries

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

Property Owners filed an action against Montgomery County, asserting a claim of regulatory taking under Tenn. Const. art. I, 21, for which they sought compensation pursuant to the inverse condemnation statute. The County filed a motion to dismiss for failure to state a claim. The trial court denied the motion. The Court of Appeals reversed in part and remanded, holding (1) the Property Owners’ regulatory takings claim should be dismissed because the Court had not yet recognized regulatory takings under the state Constitution; but (2) the Property Owners alleged facts sufficient to state a claim for inverse condemnation. The Supreme Court reversed the Court of Appeals’ judgment insofar as it reversed the trial court’s judgment and dismissed the Property Owners’ regulatory taking claim, holding (1) like the Takings Clause of the federal Constitution, Tenn. Const. art. I, 21 encompasses regulatory takings; and (2) the Property Owners’ complaint was sufficient to allege a state constitutional regulatory taking claim, for which they may seek compensation under Tennessee’s inverse condemnation statute. View "Phillips v. Montgomery County" on Justia Law

Defendant pled guilty to two counts of vehicular homicide and was sentenced to twenty-four years' imprisonment. Defendant twice appealed his sentence. On both appeals the court of criminal appeals remanded the case for resentencing, and on each remand the trial court imposed a twenty-four year sentence. No appeal was filed from the third sentencing order. Defendant subsequently filed a pro se petition for post-conviction relief, alleging that his trial counsel provided ineffective assistance by failing to appeal the third sentencing order. At the post-conviction hearing, trial counsel testified that he and Defendant discussed a third appeal and that Defendant agreed that no appeal would be filed. The post-conviction court denied post-conviction relief, finding the testimony of trial counsel to be more credible than the testimony of Defendant and concluding that Defendant knew of his right to appeal and waived that right. The Supreme Court affirmed, holding (1) trial counsel’s failure to file a written waiver of appeal as required by Tenn. R. Crim. P. 37(d)(2) did not violate Defendant’s right to effective assistance of counsel; and (2) Defendant failed to prove by clear and convincing evidence his allegations of ineffective representation. View "Arroyo v. State " on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and aggravated burglary. Defendant appealed, challenging the sufficiency of the evidence. The court of criminal appeals affirmed the convictions and sentences, holding (1) the evidence of identification was sufficient as to both convictions; and (2) as to the aggravated burglary, the victim had not given his “effective consent” to the entry of the residence. The Supreme Court (1) affirmed the aggravated robbery conviction, holding that the identification evidence was sufficient as to both offenses; but (2) reversed the aggravated burglary conviction, holding that the evidence was insufficient as a matter of law to support the conviction because no reasonable factfinder could conclude that Defendant’s entry of the residence was without the victim’s “effective consent.” Remanded for a new trial on the lesser included offenses of aggravated criminal trespass and criminal trespass. View "State v. Pope" on Justia Law

Petitioner pled guilty to the felony charge of child neglect and to the misdemeanor charge of child abuse. About six months later, Petitioner for a petition for post-conviction relief, alleging that he received ineffective assistance of counsel based on trial counsel's failure to advise him of the immigration consequences of his plea and that his plea was unknowing and involuntary because the trial court failed to comply with Tenn. R. Crim. P. 11(b)(1)(J). The post-conviction trial court denied relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) trial counsel did not perform deficiently; and (2) the trial court's failure to comply with Rule 11(b)(1)(J) was harmless beyond a reasonable doubt. View "Garcia v. State" on Justia Law

At issue in this case was a law providing that citizens who appear in person to vote must present photographic proof of their identity. The statute authorized a photographic identification card issued by the State as a valid form of identification. Plaintiffs were two residents who attempted to vote in the primary election using photographic identification cards issued by the City of Memphis Public Library. The residents and City filed a declaratory judgment action arguing (1) the photographic identification requirement violated constitutional protections, and (2) the City qualified as an entity of the State authorized to issue valid photographic identification cards through its public library. The trial court denied relief. The court of appeals affirmed in part and reversed in part, holding (1) the photographic identification requirement did not violate constitutional principles, and (2) the photographic identification cards issued by the library complied with the statute for voting purposes. On appeal, the Supreme Court held (1) the issue pertaining to the library cards as photographic identification was moot because a change in the law precluded the use of photographic identification cards issued by municipalities or their libraries for voting purposes; and (2) the photographic identification requirement met constitutional scrutiny. View "City of Memphis v. Hargett" on Justia Law

After a jury trial, Defendant was convicted of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) the sentence of death was not excessive, disproportionate, or imposed arbitrarily; (3) the evidence was sufficient to support the jury's finding of the statutory aggravating circumstances beyond a reasonable doubt; and (4) the evidence supported the jury's finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt. View "State v. Pruitt" on Justia Law

After a bench trial, Defendant was convicted of two counts of attempted first degree murder and one count each of especially aggravated burglary, attempted aggravated robbery, and aggravated assault. In sentencing Defendant, the trial judge sentenced Defendant to consecutive twenty-five year sentences for each attempted first degree murder conviction. The court of criminal appeals (1) reduced one count of attempted first degree murder to attempted second degree murder, concluding that insufficient evidence supported the convictions, and modified the conviction of especially aggravated burglary to aggravated burglary; and (2) affirmed the other convictions. The Supreme Court affirmed in part and reversed in part, holding (1) there was sufficient evidence to support Defendant's convictions of two counts of attempted first degree murder; and (2) the trial judge did not err in imposing consecutive sentencing for the two attempted first degree murder convictions. View "State v. Dickson" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law