Articles Posted in Tennessee Supreme Court

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In this case challenging the constitutionality of Tenn. Code Ann. 55-10-413(f), the Supreme Court held that the Defendant’s constitutional challenges failed. The statutory scheme at issue here imposes a fee upon persons convicted of certain drug and alcohol offenses when Tennessee Bureau of Investigation (TBI) forensic scientists have conducted chemical tests to determine blood alcohol or drug content. The statute earmarks the fees imposed to an intoxicant testing fund, and monies in the fund remain available for appropriation to the TBI as determined by the General Assembly. Defendant argued that the statutory scheme provides TBI forensic scientists with financial incentives to produce blood alcohol test results that result in convictions, which increases fees and funding for the TBI. Therefore, Defendant argued, the financial incentives create an appearance of impropriety and deprive of her her constitutional right to a fair and impartial trial. The Supreme Court held (1) the standard of neutrality announced in Tumey v. Ohio, 273 U.S. 510 (1927), and its progeny does not apply to TBI forensic scientists; (2) even if the Tumey standards applied, Defendant’s constitutional claim failed because there is no appearance of impropriety; and (3) the statute does not violate substantive due process. View "State v. Decosimo" on Justia Law

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The Supreme Court held that the Exclusionary Rule Reform Act (ERRA), Tenn. Code Ann. 40-6-108, represents an impermissible encroachment by the legislature upon the Supreme Court’s authority and responsibility to adopt exceptions to the exclusionary rule and therefore violates the Tennessee Constitution’s Separation of Powers Clause. Defendant was convicted to two counts of first degree premeditated murder and other crimes. The Supreme Court affirmed Defendant’s convictions and sentences, holding (1) in light of today’s holding that the ERRA is unconstitutional, the trial court erred when it denied Defendant’s motion to suppress in reliance on the ERRA; (2) a good-faith clerical error that results in an inconsequential variation between three copies of a search warrant required pursuant to Rule 41, in and of itself, does not entitle the moving party to suppression of the evidence collected pursuant to the warrant, and therefore, the trial court properly denied Defendant’s motion to suppress under this good-faith exception; and (3) Defendant’s remaining arguments on appeal did not warrant reversal of her convictions. View "State v. Lowe" 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

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At issue in this case was whether a Brady claim is cognizable in the context of a petition for writ of error coram nobis and whether Appellant’s petition for a writ of error coram nobis should be dismissed as time-barred even though the State was not brought into the coram nobis proceedings at the trial court level and, consequently, did not assert the statute of limitations as an affirmative defense in the trial court. Appellant filed a coram nobis petition alleging that the State committed a Brady violation. The trial court dismissed Appellant’s petition in part because it was filed after expiration of the statute of limitations. The Court of Criminal Appeals affirmed because the petition did not present newly discovered evidence warranting coram nobis relief. The Supreme Court affirmed, holding (1) an error coram nobis proceeding is not the appropriate procedural vehicle for obtaining relief from an alleged Brady violation; (2) timeliness under the statute of limitations is an essential element of a coram nobis claim that must be demonstrated on the face of the petition; (3) the facts supporting an equitable tolling request must likewise appear on the face of the petition; and (4) the trial court did not err in dismissing the coram nobis petition in this case. View "Nunley v. State" on Justia Law

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The Supreme Court reversed the judgment of the Court of Criminal Appeals reversing Defendant’s convictions for four counts of attempted voluntary manslaughter and four counts of employing a firearm during the commission of a dangerous felony and reinstated Defendant’s three convictions for attempted voluntary manslaughter and three convictions for employment of a firearm during the commission of a dangerous felony. The court held (1) the trial court did not abuse its discretion in denying Defendant’s request for a separate trial from that of his codefendants; (2) Defendant did not waive the issue of whether his multiple convictions for employing a firearm during the commission of a dangerous felony violated the prohibition against double jeopardy; and (3) Defendant’s three convictions for employing a firearm during the commission of a dangerous felony did not violate the prohibition against double jeopardy. The court remanded to the trial court for resentencing and corrected judgments. View "State v. Harbison" on Justia Law

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The Supreme Court accepted certification of questions of law from a federal district court and answered (1) for split confinement sentences, Tennessee trial judges are authorized to fix a percentage the defendant must serve in actual confinement before becoming eligible to earn work credits, and (2) Tennessee law imposes no duty on a sheriff to challenge an inmate’s sentence as improper or potentially improper. The certified questions of law arose from a lawsuit Plaintiff brought in federal district court pursuant to 42 U.S.C. 1983 alleging that his civil rights were violated when his sentence was not reduced by the work credits he earned as a trusty while confined in Madison County jail on his split confinement sentence. View "Ray v. Madison County" on Justia Law

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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

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Plaintiffs Stephen Michael West and Derrick D. Schofield were each convicted of first degree murder and sentenced to death. Plaintiffs bought a declaratory judgment action seeking a declaration that the written protocol by which the Tennessee Department of Correction carries out an execution by lethal injection violates the United States and Tennessee Constitutions. The trial court denied relief to Plaintiffs. The Supreme Court affirmed, holding that the trial court did not err in (1) concluding that Plaintiffs failed to carry their burden of demonstrating that the protocol, on its face, violates the constitutional prohibitions against cruel and unusual punishment; and (2) dismissing Plaintiffs’ claims that the protocol requires violations of federal drug laws. View "West v. Schofield" on Justia Law

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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

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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