Justia Constitutional Law Opinion Summaries

An officer responded to an anonymous 911 call reporting a speeding red Chevrolet pickup on a state route in Tennessee, including its license plate number. The officer located a vehicle matching the description, followed it, and when the driver pulled into a store parking lot, the officer parked behind the truck, blocking it in. The driver, later identified as the defendant, admitted to drinking and speeding. The officer smelled alcohol, observed slurred speech, and found a handgun on the defendant during a pat-down. The defendant failed field sobriety tests and was arrested. He was indicted for driving under the influence, possession of a handgun while under the influence, possession of a handgun by a convicted felon, and violation of the implied consent law.The Criminal Court for Polk County denied the defendant’s motion to suppress evidence, finding that the officer seized the defendant by blocking his vehicle but had reasonable suspicion based on the corroborated anonymous tip. The defendant, pursuant to a plea agreement, pled guilty to DUI and handgun possession while reserving the right to appeal a certified question of law about the constitutionality of the seizure. The Court of Criminal Appeals dismissed the appeal, holding that the certified question failed to meet the requirements of Tennessee Rule of Criminal Procedure 37(b)(2) as interpreted by the Tennessee Supreme Court in State v. Preston, because it did not clearly identify the scope and limits of the legal issue reserved.The Supreme Court of Tennessee reviewed the case to determine if the procedural requirements for a certified question were met and whether to revise the certified-question procedure. The court held that appellate courts must consider the certified-question statement together with the record when determining if the scope and limits requirement is satisfied. Applying this standard, the court found that all requirements were met, reversed the dismissal, and remanded the case for consideration of the merits. View "State of Tennessee v. Burrell" on Justia Law

A seventeen-year-old defendant was implicated in the fatal shootings of two individuals at an apartment complex in Milan, Tennessee. Law enforcement identified the defendant and a co-defendant as suspects based on anonymous tips and information from onlookers. The defendant was interrogated at the police station without the presence of his mother, despite her being at the station and his repeated requests for her. Over the course of nearly seven hours, he ultimately confessed to participating in the shootings after being told, among other things, that he could face the death penalty and subjected to other coercive tactics. No weapons were recovered, but ballistics indicated two firearms were used. Cell phone records and eyewitness testimony linked the defendant to the scene.The Gibson County Juvenile Court held a transfer hearing and, after considering statutory factors and the evidence presented, found probable cause and transferred the defendant to Circuit Court to be tried as an adult. The court suppressed the defendant’s confession for purposes of the transfer decision. Subsequently, the Circuit Court denied a motion to suppress the confession, finding it voluntary and admissible. At trial, the defendant was convicted by a jury of two counts of second-degree murder. The Tennessee Court of Criminal Appeals affirmed, holding that the transfer was appropriate and the confession voluntary.The Supreme Court of Tennessee reviewed the case. It held that the juvenile court properly transferred the defendant after finding probable cause and satisfying all statutory requirements. The Supreme Court further held that the defendant validly waived his Fifth Amendment right to remain silent. However, the court found that the confession was involuntary, having been obtained through coercion in violation of the Due Process Clause. As a result, the Supreme Court vacated the convictions and remanded the case for further proceedings, excluding the coerced confession from any retrial. View "State v. Adkisson" on Justia Law

Three documents related to a criminal case in Davidson County were filed and sealed without a written order by the presiding judge, who subsequently recused herself. After the case was transferred to a new trial court, a news organization sought to intervene and unseal the documents, which included a motion for judicial disqualification and supporting affidavits. The documents were not listed on the public docket, and the clerk’s office explained that they were marked “Filed Under Seal” by the preparer, but no formal order authorized the seal.The Criminal Court for Davidson County allowed the news organization to intervene but denied its motion to unseal the documents. The trial court found that more compelling interests were at stake, including the risk of publishing unsupported claims, potential embarrassment or burden to involved persons, and possible delays or denials of due process. The court ordered that the documents remain sealed and later issued a separate order citing confidentiality under Supreme Court rules. The news organization then sought review in the Tennessee Court of Criminal Appeals, which denied both an extraordinary appeal and a writ of certiorari, concluding that interlocutory appeal was not available to media intervenors in criminal cases.The Supreme Court of Tennessee granted review to address the availability of interlocutory appeals for media intervenors and the standard for sealing judicial records. The court held that such appeals are available to media intervenors when judicial proceedings are closed or records are sealed. The court further ruled that sealing judicial records protected by the First Amendment requires a written order identifying a compelling interest and that the seal must be narrowly tailored. After conducting a de novo review, the court found no compelling interest justifying the seal and ordered the documents to be made public, reversing the Court of Criminal Appeals. View "State of Tennessee v. Johnson" on Justia Law

The plaintiff, an at-will employee, was terminated by her employer, a private organization, after she sent emails to members of the Tennessee General Assembly expressing grievances about the employer's COVID-19 vaccination mandate. The employer claimed the emails violated its policies. The plaintiff sued for retaliatory discharge, asserting her termination violated her right to petition under Article I, Section 23 of the Tennessee Constitution.The Chancery Court for Hamilton County dismissed the complaint, holding that the right to petition did not apply to private employers. The Court of Appeals reversed, finding that the right to petition could serve as a public policy exception to the employment-at-will doctrine, thus allowing the plaintiff's claim to proceed.The Supreme Court of Tennessee reviewed the case and held that the right to petition in the Tennessee Constitution is enforceable only against governmental entities, not private parties. The court emphasized that the historical context of the right to petition, dating back to early England, was intended to protect against government oppression, not to constrain private parties. The court noted that no state has held that the right to petition limits the ability of private employers to terminate at-will employees. Consequently, the court concluded that private employers do not violate a clear public policy by terminating employees for exercising the right to petition.The Supreme Court of Tennessee reversed the Court of Appeals' decision and affirmed the trial court's dismissal of the plaintiff's complaint, holding that at-will employees cannot base claims of retaliatory discharge against private employers on the right to petition in the Tennessee Constitution. View "Smith v. BlueCross BlueShield of Tennessee" on Justia Law

Robin M. McNabb, a former Municipal Court Judge for Lenoir City, filed an election contest against Gregory H. Harrison, who won the election for the same position in 2022. McNabb argued that Harrison was ineligible to serve because he had not resided within the Lenoir City corporate limits for the year preceding the election, as required by Article VI, Section 4 of the Tennessee Constitution.The Chancery Court for Loudon County found that the term "district" in Article VI, Section 4 referred to the modern-day judicial district. Since Harrison resided in the Ninth Judicial District, the court ruled him eligible to serve. The Court of Appeals affirmed the trial court's decision but modified the judgment, stating that "district" referred to Loudon County, not the Ninth Judicial District, because the Lenoir City Municipal Court has concurrent jurisdiction with the Loudon County General Sessions Court.The Supreme Court of Tennessee reviewed the case and disagreed with the lower courts. It held that Article VI, Section 4 requires a candidate for a municipal judgeship to be a resident of the same municipality to which they will be assigned. Therefore, Harrison needed to reside in Lenoir City for one year prior to the election. The Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the Chancery Court for further proceedings consistent with this opinion. View "McNabb v. Harrison" on Justia Law

Leah Gilliam had a personalized license plate reading "69PWNDU" for over a decade. The State of Tennessee revoked the plate, deeming it offensive. Gilliam sued state officials, claiming that Tennessee's personalized license plate program discriminates based on viewpoint, violating the First Amendment. The State argued that the alphanumeric characters on personalized plates are government speech, not subject to the First Amendment's prohibition of viewpoint discrimination.The Davidson County Chancery Court, a three-judge panel, ruled in favor of the State, concluding that the alphanumeric combinations on personalized plates are government speech. The Court of Appeals reversed this decision, finding that the personalized plates are private speech. The appellate court focused on the history of personalized plates, public perception, and the State's control over the messages, concluding that these factors did not support the State's argument.The Supreme Court of Tennessee reviewed the case and reversed the Court of Appeals' decision. The court held that the alphanumeric combinations on Tennessee's personalized license plates are government speech. The court applied the reasoning from Walker v. Texas Division, Sons of Confederate Veterans, Inc., which held that Texas's specialty license plate designs were government speech. The court found that the history of license plates, public perception, and the State's control over the messages all supported the conclusion that personalized alphanumeric combinations are government speech. Consequently, the court reinstated the trial court's judgment in favor of the State. View "Gilliam v. Gerregano" on Justia Law

Robert E. Lee Flade filed a lawsuit against several defendants, including Stephanie Isaacs and the Bedford County Listening Project (BCLP), over disparaging remarks made on social media. Isaacs and the BCLP filed motions to dismiss under Rule 12.02(6) of the Tennessee Rules of Civil Procedure and petitions to dismiss under the Tennessee Public Participation Act (TPPA), seeking dismissal with prejudice, attorney’s fees, and sanctions. Before the trial court could hear these motions, Flade voluntarily dismissed his complaint without prejudice. Isaacs and the BCLP requested the court to adjudicate their TPPA petitions despite the dismissal, but the trial court declined, stating the nonsuit concluded the matter.The Court of Appeals affirmed the trial court’s decision, holding that the TPPA petitions did not limit Flade’s right to a voluntary nonsuit under Rule 41.01(1). The court reasoned that the TPPA did not specifically limit the right to a nonsuit and that the mere filing of a TPPA petition did not create a vested right that would prevent a voluntary dismissal.The Supreme Court of Tennessee reviewed the case and affirmed the Court of Appeals' judgment. The court held that the right to take a voluntary nonsuit is not subject to the provisions of the TPPA under Rule 41.01(1). It also concluded that there is no vested right to adjudication of a TPPA petition pending at the time of a voluntary nonsuit and that a TPPA petition does not constitute a counterclaim for purposes of Rule 41.01(1). Therefore, the trial court correctly declined to adjudicate the TPPA petitions after Flade voluntarily dismissed his complaint. View "Flade v. City of Shelbyville, Tennessee" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court's summary judgment to the three named state official defendants in this complaint seeking a temporary injunction related to the August 6, 2020 election, holding that Plaintiff was required to comply with both Tenn. Code Ann. 2-19-143(3) and Tenn. Code Ann. 40-29-202 before he could be re-enfranchised.Plaintiff, a Tennessee resident since 2018, was convicted in 1986 of involuntary manslaughter in Virginia. In 2020, the governor of Virginia granted Plaintiff clemency, thus reinstating his right to vote in Virginia. Later that year, Plaintiff attempted to register to vote in Grainger County, Tennessee but was denied. Plaintiff brought this lawsuit arguing that Tenn. Code Ann. 2-19-143(3) requires the state to re-enfranchise persons convicted of infamous crimes out of state when the governor or the appropriate authority of such other state restores that person's rights of citizenship. The chancery court granted summary judgment for Defendants, and the court of appeals affirmed. The Supreme Court affirmed, holding that, to regain the right of suffrage in Tennessee, Plaintiff and other similarly situated individuals must comply with both Tenn. Code Ann. 2-19-143(3) and the additional requirements set forth in Tenn. Code Ann. 40-29-202. View "Falls v. Goins" on Justia Law

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's convictions and reinstated the judgments of the trial court, holding that the intermediate court erred when it stated that an involuntary confession claim is "inextricably linked" to a Miranda waiver claim such that the two inquiries can be considered together.Defendant, a juvenile at the time of the offenses, was convicted of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. Defendant was sentenced to life in prison for the murder conviction. On appeal, the court of criminal appeals reversed the denial of Defendant's motion to suppress pretrial statement to detectives, concluding that the statement was not voluntary. The Supreme Court reversed, holding (1) Defendant's overall statement was voluntary, and his Miranda waiver was both knowing and voluntary; and (2) the evidence presented by the State was sufficient to support Defendant's conviction for premeditated first-degree murder. View "State v. McKinney" on Justia Law

Phillips was convicted of offenses, including felony murder, attempted first-degree murder, aggravated rape, especially aggravated kidnapping, and especially aggravated burglary. The Court of Criminal Appeals modified the especially aggravated burglary conviction to aggravated burglary. Phillips sought post-conviction relief, asserting that his trial counsel was constitutionally ineffective by failing to seek suppression of various statements he made to police. The Court of Criminal Appeals affirmed the denial of relief.The Tennessee Supreme Court affirmed, clarifying the petitioner’s burden to establish prejudice when he alleges counsel was constitutionally ineffective for failing to file a motion to suppress on Fourth Amendment grounds: The petitioner must prove that his Fourth Amendment claim is meritorious and that there is a reasonable probability that the verdict would have been different absent the excludable evidence. Despite the Fourth Amendment concerns brought about by the Memphis Police Department’s use of a 48-hour hold policy, there is no proof that the probable cause determination was unreasonably delayed and Phillips’s arrest was supported by probable cause. Given the proof of his guilt, Phillips has not established a reasonable probability that his verdict would have been different had his statements to the police been suppressed. View "Phillips v. State of Tennessee" on Justia Law