Justia Constitutional Law Opinion Summaries

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

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

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

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

Defendant was convicted of two counts of premeditated first-degree murder and one count of felony murder in the perpetration of a kidnapping. Defendant was sentenced to death on each conviction. The Court of Criminal Appeals upheld Defendant’s two convictions of first degree murder. The Supreme Court affirmed the convictions and sentences, holding (1) the trial court did not violate Defendant’s right against self-incrimination or Defendant’s Sixth Amendment right to counsel by admitting into evidence certain incriminating statements Defendant made to his ex-wife; (2) the searches of Defendant’s home and storage unit did not violate the Fourth Amendment; (3) the trial court did not abuse its discretion in declining to exclude certain photographs of the victims and in denying Defendant’s ex parte motions for a crime scene expert and a false confession expert; (4) the sentences of death were not imposed in an arbitrary fashion and were neither excessive of disproportionate; and (5) the evidence supported the jury’s findings as to each first degree murder conviction. View "State v. Willis" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault committed by violating a protective order, and evading arrest. Defendant appealed, arguing that the trial court’s failure to compel the State to elect an offense as to the aggravated assault charge resulted in plain error. The Court of Criminal Appeals affirmed, concluding that, based upon the indictment and the State’s closing argument, Defendant’s right to a unanimous jury verdict was not violated. The Supreme Court affirmed Defendant’s conviction for evading arrest but reversed Defendant’s conviction for aggravated assault and remanded the matter for a new trial on that charge, holding that the failure to elect in this case was not harmless beyond a reasonable doubt. View "State v. Smith" on Justia Law

Defendant Christopher Davis was convicted of two counts of premeditated first degree murder, two counts of especially aggravated kidnapping, and two counts of especially aggravated robbery. The jury imposed death sentences for both counts of premeditated first degree murder after finding that evidence of three aggravating circumstances. In addition, the trial court sentenced the defendant to concurrent 25-year sentences for the especially aggravated kidnapping convictions to run consecutively to concurrent 25-year sentences for the especially aggravated robbery convictions. After the Court of Criminal Appeals affirmed the convictions and the sentences, the case was automatically docketed to the Supreme Court. Finding no reason to disturb the lower courts' judgments, the Supreme Court affirmed the conviction and sentences. View "Tennessee v. Davis" on Justia Law

In 1986, petitioner Torian Benson, a.k.a Marcus Terry, a.k.a Marcus Benson, pled guilty in to four counts of larceny and six counts of robbery, for which he was sentenced to three years imprisonment for each larceny count and five years for each robbery count. All sentences were ordered to be served concurrently, resulting in an effective sentence of five years. In 1989, petitioner entered guilty pleas to two counts of larceny and one count of aggravated assault, for which he was sentenced to three years for each count, all to be served concurrently, for an effective total sentence of three years. In 1993: petitioner entered a guilty plea to one count of theft of property over $10,000 and was sentenced to four years imprisonment; petitioner pled guilty to unlawful possession of a controlled substance with intent to sell and was sentenced to a term of eight years; and petitioner pled guilty to two counts of possession of a controlled substance and received an eight-year sentence for one count and a four-year sentence for the other. All of the 1993 convictions were ordered to be served concurrently. In 1997, petitioner was found guilty of two counts of vehicular homicide and sentenced to a term of fifteen years for each count. Based upon the petitioner’s prior convictions, the trial court found the petitioner to be a “career offender.” Under the sentencing guidelines, this designation required the court to impose the maximum sentence for felony offenses, which in the case of vehicular homicide was fifteen years. The trial court ordered both fifteen-year sentences to be served consecutively, not only with each other but also with another four-year sentence. In 2002, acting pro se, petitioner filed three separate petitions for writs of habeas corpus challenging the validity of the 1986, 1989 and 1993 convictions. The Court of Criminal Appeals affirmed the trial court’s denial of habeas corpus relief. Along with affirming the trial court’s initial findings, the intermediate court also held that habeas corpus relief was not available because the petitioner was not eligible for immediate release as he then-currently incarcerated on charges unrelated to those challenged in the petitions. Finding no reversible error as to the denial of habeas relief, the Tennessee Supreme Court affirmed. View "Benson v. Tennessee" on Justia Law

Defendant Delawrence Williams was indicted for possession of over one-half gram of cocaine with the intent to sell or deliver. He filed a motion to suppress the evidence, arguing that probable cause had not been shown for the issuance of a search warrant. The Court of Criminal Appeals affirmed the trial court’s decision to deny the motion to suppress. The Supreme Court granted this interlocutory appeal to review: (1) whether the information used to obtain a search warrant to search the defendant’s residence was provided by a “citizen informant” and presumptively reliable; and (2) whether the information, if not provided by a “citizen informant,” nonetheless established probable cause under "Tennessee v. Jacumin," (778 S.W.2d 430 (Tenn. 1989)). After reviewing the record and applicable authority, the Supreme Court held: (1) that the trial court and the Court of Criminal Appeals properly granted the interlocutory appeal pursuant to Rule 9 of the Tennessee Rules of Appellate Procedure; and (2) that although the information used to obtain the search warrant for the defendant’s residence was not provided by a “citizen informant,” it established probable cause under the two-prong analysis in Jacumin. The judgment was therefore affirmed. View "Tennessee v. Williams" on Justia Law

After a jury trial, Defendant was convicted of first offense driving under the influence. Defendant filed a motion for a new trial, arguing that the trial court erred by denying his motion to suppress on the grounds that the warrantless seizure of his parked vehicle and the ensuing field sobriety tests were not supported by reasonable suspicion. The trial court denied the motion. The Court of Criminal Appeals affirmed, concluding that the arresting officer’s activation of his patrol car’s rear blue lights was an exercise of the community caretaking function and not a seizure.The Supreme Court affirmed, holding (1) the Court’s decision in State v. Moats, which held that the community caretaking doctrine is not an exception to the federal and state constitutional warrant requirements, was wrongly decided and is hearby overruled; (2) the community caretaking exception is an exception to the state and federal constitutional warrant requirements that may be invoked to validate as reasonable a warrantless seizure of an automobile; and (3) the community caretaking exception applies in this case. View "State v. McCormick" on Justia Law