Justia Constitutional Law Opinion Summaries

Petitioner Henry Felts was convicted of aggravated burglary and attempted murder. Petitioner filed a petition for post-conviction relief, alleging ineffective assistance of counsel. The post-conviction court vacated Petitioner's conviction, finding that trial counsel's representation was ineffective because he (1) failed to pursue the defense of attempted voluntary manslaughter and (2) advised Petitioner not to testify when he had promised the jury that Petitioner would testify. The court of criminal appeals affirmed. The Supreme Court reversed, holding that the courts below erred in finding trial counsel's performance deficient where (1) trial counsel chose a single, reasonable defense theory to the exclusion of another plausible, but inconsistent theory; and (2) trial counsel's decision not to call Petitioner as a witness was consistent with his altered trial strategy.

Defendant was indicted for a murder that occurred nearly ten years prior to his arrest. Defendant's theory of the case implicated two other men, who had previously been tried and acquitted of the murder, as the individuals responsible for the murder. Over the objection of Defendant, the State introduced evidence of the prior acquittals of the other men. A jury convicted Defendant of facilitation of first degree murder. The court of criminal appeals reversed, holding that the evidence of the acquittals of the other parties was irrelevant and that the erroneous admission of the evidence was not harmless. The Supreme Court affirmed, holding (1) under the facts of this case, the evidence of a prior acquittal of an individual for the crime for which the defendant is on trial is not relevant as context evidence, relevant to the credibility of the witness, or relevant to rebut a defense theory that the other individual committed the crime; and (2) the erroneous admission of the evidence was not harmless. Remanded for a new trial.

After a jury trial, Defendant Joshua Parker was convicted of second degree murder and attempted rape. The court of criminal appeals affirmed. The Supreme Court affirmed Defendant's conviction of attempt to commit rape but reversed and vacated Defendant's conviction of second degree murder, holding (1) there was insufficient evidence to support Defendant's conviction, (2) State v. Mellons did not control the outcome of this case, (3) sufficient proof must support every element of the offense of which a defendant is convicted, even where the conviction offense is charged as a lesser-included offense and sufficient proof supports the greater offense, and (4) the trial court erred in charging the jury with second degree murder as a lesser-included offense of first degree felony murder. Because the proof was sufficient to support the offense of reckless homicide, remanded for entry of an amended judgment reflecting a conviction of reckless homicide and sentencing on reckless homicide.

Defendant pled guilty to attempted aggravated sexual battery and was sentenced to six years of enhanced probation. During the proceedings, the trial court did not warn Defendant that, upon the expiration of his sentence, he would be subjected to lifetime community supervision, which is mandated by statute for Defendant's conviction. Before Defendant's sentence expired, the State filed a petition to amend the judgment to include lifetime community supervision. The trial court corrected the judgment, and Defendant filed a motion to withdraw his guilty plea. The trial court denied the motion. The court of criminal appeals affirmed, holding that Defendant had been adequately informed of the lifetime community supervision requirement by his trial counsel. The Supreme Court reversed, holding that because the trial court failed to warn Defendant of the mandatory nature of lifetime community supervision, as was required by the Court's recent ruling in Ward v. State, and because the State was unable to establish that the error was harmless beyond a reasonable doubt, Defendant was permitted to withdraw his guilty plea. Remanded.

Employee suffered a work-related injury and sought benefits. The benefit review conference at the Department of Labor and Workforce Development (DOL) ended in an impasse after a dispute about the degree of Employee's medical impairment. Employee filed suit. Subsequently, Employer filed an application for medical impairment rating (MIR) with the DOL, seeking the appointment of an independent medical examiner pursuant to Tenn. Code Ann. 50-6-204(d)(5). The trial court granted Employee's motion to quash the MIR, holding that the statute was established for the purpose of resolving workers' compensation claims while the claim was before an administrative body, and therefore, DOL had relinquished jurisdiction when the benefit review process reached an impasse. The trial court then adopted the higher of the disputed impairment ratings. The Supreme Court vacated the judgment of the trial court, holding (1) the constitutional separation of powers question was not properly presented, argued, or litigated before the trial court; and (2) whether the Employer may attempt to resolve the dispute of degree of medical impairment by seeking the opinion of an independent medical examiner pursuant to the statute was an issue for the Employee, Employer, and Attorney General to address on remand.

Defendant Gary Wade was convicted of aggravated burglary, theft of $10,000 or more but less than $60,000, and theft of $1,000 or more but less than $10,000. The trial court classified Wade as a career offender. On appeal, the court of criminal appeals found (1) that the conviction for theft of $1,000 or more but less than $10,000 violated the prohibition against double jeopardy and was therefore dismissed; (2) that, if properly convicted of the remaining offenses, the defendant qualified as a persistent rather than a career offender; and (3) the evidence was insufficient to support the convictions for aggravated burglary and theft of $10,000 or more but less than $60,000. The State appealed. The Supreme Court (1) reversed the judgment of the appellate court with regard to two of the convictions, holding that the evidence presented at trial warrants reinstatement of the convictions for aggravated burglary and theft of property with a value of $10,000 or more but less tan $60,000; and (2) affirmed the appellate court's determination that Wade qualifies as a persistent rather than career offender. Remanded.

Defendant Cedric Johnson was charged with committing an aggravated robbery and was separately charged with initiating a false police report. Within one month of being indicted for initiating a false police report, Defendant pled guilty to the offense. The trial record revealed that Defendant's car was used in the robbery, and in order to thwart discovery by the police, Defendant reported the car as stolen. The grand jury indicted Defendant for aggravated robbery. Defendant filed a motion to dismiss the robbery indictment, arguing that he had already been prosecuted for filing the false report in connection with the robbery. The trial court granted Defendant's motion, and the State appealed. The issue before the Supreme Court pertained to offenses arising from the same criminal episode. In the Defendant's case, the Court found that the two offenses were not part of the same episode, and therefore, the appellate court erred in affirming the trial court's dismissal of the robbery charge. The Court remanded the case for further proceedings.