Justia Constitutional Law Opinion Summaries

Articles Posted in Tennessee Supreme Court

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The Supreme Court reversed the judgment of the court of criminal appeals affirming the judgment of the trial court ruling that certain portions of the Public Safety Act of 2016 (the PSA) were facially unconstitutional on grounds of separation of powers, due process, and equal protection, holding that the constitutionality of the PSA provisions at issue was not ripe for consideration by the trial court. Defendant A.B. Price, Jr. attempted to plead nolo contendere to sexual battery, and defendant Victor Sims attempted to plead guilty to aggravated assault. The trial court declared the portions of the PSA facially unconstitutional, accepted Defendants' pleas, and inserted in each judgment the special conviction that the probated portion of defendants sentences were not subject to the PSA. The court of criminal appeals affirmed. The Supreme Court reversed, holding that the constitutional issues identified and ruled upon by the courts below were not ripe for adjudication. View "State v. Price" 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 question these consolidated cases presented for the Tennessee Supreme Court's review centered on whether the trial court erred in suppressing evidence seized from the defendants’ residences in the 19th Judicial District because the warrants were signed by a Judge of the 23rd Judicial District. The Court held that, in the absence of interchange, designation, appointment, or other lawful means, a circuit court judge in Tennessee lacks jurisdiction to issue search warrants for property located outside the judge’s statutorily assigned judicial district. Nothing in the record on appeal established the 23rd Judicial District Circuit Court Judge obtained jurisdiction to issue search warrants for property in the 19th Judicial District. As a result, the searches were constitutionally invalid. The judgment of the Court of Criminal Appeals, which upheld the trial court’s order granting the defendants’ motions to suppress was affirmed. View "Tennessee v. Frazier" on Justia Law

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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