Justia Civil Rights Opinion Summaries

Defendant, convicted of felony murder and sentenced to life in prison, appealed, alleging a number of errors in the conduct of the trial, particularly the trial court's failure to suppress a statement Defendant had made to the police. The court of criminal appeals held that the admission of the statement qualified as harmless error. The Supreme Court granted Defendant's application for permission to appeal in order to determine the propriety of Defendant's arrest and to consider whether the court of criminal appeals had used the appropriate standard of review in its harmless error analysis. The Supreme Court then affirmed the judgment, holding that the arrest of Defendant was supported by probable cause and there was no other prejudicial error during the course of the trial. View "State v. Echols" on Justia Law

Plaintiffs alleged that Davidson County Sheriff's officers arrested and wrongfully interrogated and detained them while officers investigated Plaintiffs' immigration status pursuant to the October 2009 Memorandum of Agreement (MOA) entered into between the Davidson County Sheriff's Office (DCSO) and the United States Immigration and Customs Enforcement (ICE). The MOA authorized selected DCSO personnel to perform certain immigration officer duties after being trained and certified by ICE. The Supreme Court accepted certification to answer whether the MOA violated the Charter of Nashville and Davidson County. The Court held (1) the MOA did not violate the Charter or any other state law cited by Plaintiffs; and (2) the Sheriff of Davidson County had authority under the Charter to perform the duties enumerated in the MOA. View "Renteria-Villegas v. Metro. Gov't of Nashville & Davidson County " on Justia Law

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

Defendant was found guilty of one count of facilitation of aggravated burglary and two counts of theft of property. After finding the presence of one enhancement factor, the trial court imposed concurrent three-year sentences for each offense. The court of criminal appeals found the enhancement factor did not apply and reduced each of the sentences to two years. The Supreme Court reversed the sentence modification by the court of criminal appeals and reinstated the sentence imposed by the trial court, holding (1) a sentence imposed by a trial court should be upheld so long as it is within the appropriate sentencing range and is otherwise in compliance with the purposes and principles of the sentencing statute; and (2) notwithstanding the trial court's reliance on an erroneous enhancement factor in this case, its imposition of three-year sentences was supported by the reasons articulated in the record. View "State v. Bise" on Justia Law

An officer stopped Defendant for a traffic violation. When the officer ordered Defendant out of his vehicle to sign the citation, he observed what appeared to be a bag of cocaine on the floorboard of the driver's side. Charged with possession with intent to sell or deliver twenty-six grams or more of cocaine in a school zone, Defendant moved to suppress the evidence as the product of an unlawful seizure. The trial court sustained the motion, concluding that the request to exit the vehicle was not reasonably related to the stop. The court of criminal appeals affirmed. The Supreme Court reversed the order of suppression and remanded the cause for trial, holding than an officer, after making a lawful stop for a traffic violation, may routinely direct the driver outside of the vehicle.

During a robbery, one of the defendants shot the victim in the leg. Although the bullet passed through the victim's leg, the wound required minimal medical treatment and did not cause the victim to suffer a loss of consciousness, extreme pain, disfigurement, or impairment. The defendants were convicted of especially aggravated robbery and aggravated robbery. The court of criminal appeals affirmed the convictions. The Supreme Court modified the convictions for especially aggravated robbery to convictions for aggravated robbery because the victim did not suffer a serious bodily injury as required by Tenn. Code Ann. 39-13-403. Remanded to the trial court for resentencing.

Employee was discharged after she filed complaints with the Equal Employment Opportunity Commission and a lawsuit against Employer alleging employment discrimination. Employee appealed the termination to the Metro Civil Service Commission (Commission) and eventually settled the appeal, receiving backpay and other consideration in exchange for her agreement not to accept future employment with the agency that discharged her. Employee subsequently filed a complaint against Employer alleging violations of the Civil Rights Act and Age Discrimination in Employment Act. The trial court granted summary judgment in favor of Employer, reasoning that Employee could not establish her termination constituted an adverse employment action because she had accepted backpay and agreed not to be reinstated as part of the settlement of her Commission appeal. The court of appeals affirmed. The Supreme Court reversed, holding that Employee's acceptance of the settlement did not preclude her from establishing that her termination constituted an adverse employment action for purposes of her federal retaliatory discharge claims.

After an investigatory stop and frisk, Defendant was charged with the unlawful possession of a handgun after a felony conviction and the unlawful possession of a handgun while under the influence of alcohol and was convicted on both counts. Defendant appealed, arguing that his motion to suppress evidence should have been granted. The court of criminal appeals affirmed. The Supreme Court reversed the judgments of conviction and dismissed the cause, holding that because the investigatory stop and frisk of Defendant was not supported by specific and articulable facts establishing reasonable suspicion that a criminal act was being or about to be committed, the trial court erred by failing to suppress the handgun found by the police and presented as evidence at trial.

Defendant was tried and convicted of two counts of first degree murder and sentenced to death for each offense. The court of criminal appeals affirmed. The Supreme court affirmed in part and reversed in part, holding (1) the trial court erred by admitting detailed evidence of a prior claim of child sex abuse and by allowing references to Defendant's refusal to submit to a polygraph examination; (2) the prosecutor committed misconduct during the opening statement and during the final arguments of both the guilty and penalty phases of the trial; (3) however, the errors were harmless, and therefore, the convictions were affirmed; but (4) because certain of the inadmissible evidence was particularly inflammatory and the prosecution made several inappropriate comments, the sentences of death must be set aside. Remanded for new sentencing hearings.

Father and Mother were jointly tried on two counts of felony murder and three counts of aggravated child abuse as a result of the death of their child. Only Mother testified in her own defense. During direct examination, Mother did not testify about prior incidents in which Father assaulted her. On cross-examination, Father's counsel asked Mother whether she believed Father was capable of hurting the victim. The trial court ruled sua sponte that counsel for Father had "opened the door" to cross-examination about Father's assaults against Mother. Father was subsequently convicted of felony murder and aggravated child abuse. Mother was convicted of facilitation of felony murder and aggravated child abuse. The Supreme Court reversed Mother's conviction, holding that the evidence of prior assaults by Father was inadmissible and that the parties did not open the door to cross-examination about Father's assaults against Mother. Remanded for a new trial.