Justia Constitutional Law Opinion Summaries

Four university football players were indicted for criminal charges arising out of the alleged rape of a university student. Petitioners, a group of media organizations and a citizens group, made a Public Records Act request to inspect the police department’s files regarding its investigation of the football players. The police department denied the request. Petitioners filed a petition against the police department seeking access to the requested records under the Tennessee Public Records Act. The Court of Appeals concluded that all of the requested materials were relevant to a pending or contemplated criminal action and were therefore exempt from public disclosure under Tenn. R. Crim. P. 16. The Supreme Court affirmed on different grounds, holding (1) during the pendency of a criminal case and any collateral challenges to any conviction, Rule 16 governs the disclosure of information, and only the defendants, not the public, may receive information contained in the police investigative files; and (2) based on Rule 16, Petitioners have no right to the requested information during the pendency of the criminal cases and any collateral challenges to any convictions. View "The Tennessean v. Metro. Gov’t of Nashville & Davidson County" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the admission into evidence of an autopsy report through the testimony of a medical examiner who did not perform the autopsy was not testimonial, so its admission into evidence did not violate Defendant’s rights under the Confrontation Clause; (2) the responding officer’s initial entry into Defendant’s home was justified by exigent circumstances, and the subsequent entry into the home by other officers was a continuation of the responding officer’s entry into the home, and therefore, the trial court properly denied Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting into evidence items that were not in plain view during the warrantless search, the error was harmless. View "State v. Hutchison" on Justia Law

Defendant was stopped after a police officer observed him cross the double yellow center lane lines with the two left wheels of his car. Defendant was subsequently charged with driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the arresting officer’s seizure of Defendant did not violate Defendant’s constitutional rights, and therefore, the trial court did not err in denying Defendant’s motion to suppress. View "State v. Davis" on Justia Law

Defendant was stopped after a police officer observed Defendant cross once and touch twice the fog line marking the outer right lane boundary on an interstate highway. Defendant was subsequently charged with alternative counts of driving under the influence. Defendant moved to suppress the evidence, arguing that the traffic stop was unconstitutional. The trial court denied the motion to suppress. Thereafter, Defendant pleaded guilty to driving under the influence. The Supreme Court affirmed, holding that the traffic stop of Defendant did not violate his constitutional rights because it was supported by reasonable suspicion. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of three counts of facilitation of first degree murder and one count of facilitation of aggravated robbery. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err in admitting an autopsy report through the testimony of a medical examiner who did not perform the autopsy, as the autopsy report was not testimonial and therefore did not violate Defendant’s rights under the Confrontation Clause; (2) the warrantless search of Defendant’s home by officers who entered the home after the first responding officer’s initial entry into the home was lawful, and consequently, the trial court did not err by denying Defendant’s motion to suppress the evidence that was in plain view and within the scope of the search; and (3) even if the trial court erred in admitting items that were not in plain view, the error was harmless. View "State v. Hutchison" on Justia Law

Mortgage Electronic Registration Systems, Inc. (MERS) brought this action to set aside a tax sale of real property, arguing that the county’s failure to provide it with notice of the sale violated his right to due process. The purchaser of the real property (Defendant) moved for judgment on the pleadings, asserting that MERS did not tender payment of the sale price plus the accrued taxes before bringing suit, as is statutorily required in a suit challenging the validity of a tax sale, and that MERS did not have a protected interest in the subject property. The trial court granted Defendant’s motion, concluding that MERS did not have an interest in the property. The Court of Appeals on the grounds that MERS lacked standing to file suit. The Supreme Court affirmed on different grounds, holding (1) MERS was not required to tender payment before filing this lawsuit; and (2) MERS acquired no protected interest in the subject property, and therefore, its due process rights were not violated by the county’s failure to notify it of the tax foreclosure proceedings or the tax sale. View "Mortgage Elec. Registration Sys., Inc. v. Ditto" on Justia Law

Defendant was convicted of first degree premeditated murder, first degree felony murder, and related offenses. The trial court imposed a sentence of death based on three aggravating circumstances. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the court of criminal appeals did not err by affirming the trial court’s denial of Defendant’s motion to suppress statements he gave to law enforcement officers on the basis that the confessions were knowingly and voluntarily made; and (2) Defendant’s death sentence was not imposed arbitrarily, the evidence supported the trial court’s finding that the aggravating circumstances outweighed any mitigating circumstances beyond a reasonable doubt, and the sentence of death was not disporportionate. Remanded for entry of a corrected judgment reflecting the trial court’s merger of Defendant’s convictions for first degree murder into a single conviction. View "State v. Freeland" on Justia Law

After a jury trial, Defendant was convicted of second degree murder. The court of criminal appeals affirmed. The Supreme Court vacated Defendant’s conviction and sentence, holding (1) the lead prosecutor violated Defendant’s constitutional right against self-incrimination during final closing argument by making a remark that the jury necessarily would have taken to be a comment on Defendant’s exercise of her constitutional right not to testify; (2) the prosecution violated Defendant’s constitutional right to due process by failing to provide to the defense until after the trial the third statement a key witness gave to law enforcement officers investigating the murder; and (3) these constitutional errors were not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Jackson" on Justia Law

Petitioner entered best interest guilty pleas to attempted first degree murder, second degree murder, and especially aggravated robbery. Petitioner later filed a petition for post-conviction relief, claiming ineffective assistance of counsel and that his guilty pleas were not knowingly and voluntarily made. Petitioner requested that the post-conviction court issue subpoenas for his three co-defendants, who were incarcerated at the time, to testify at the post-conviction hearing. The post-conviction court granted the State’s motion to quash because the defendants were incarcerated. After a subsequent hearing, the post-conviction court denied post-conviction relief. The court of criminal appeals concluded that the post-conviction court erred in refusing to allow Petitioner to present witnesses in support of his claims, but that the error was harmless. The Supreme Court reversed, holding that the post-conviction court committed prejudicial error by applying an incorrect legal standard and by overlooking the relationship between the proffered testimony and Petitioner’s claim of ineffective assistance of counsel. Remanded. View "Taylor v. State" on Justia Law

Property Owners filed an action against Montgomery County, asserting a claim of regulatory taking under Tenn. Const. art. I, 21, for which they sought compensation pursuant to the inverse condemnation statute. The County filed a motion to dismiss for failure to state a claim. The trial court denied the motion. The Court of Appeals reversed in part and remanded, holding (1) the Property Owners’ regulatory takings claim should be dismissed because the Court had not yet recognized regulatory takings under the state Constitution; but (2) the Property Owners alleged facts sufficient to state a claim for inverse condemnation. The Supreme Court reversed the Court of Appeals’ judgment insofar as it reversed the trial court’s judgment and dismissed the Property Owners’ regulatory taking claim, holding (1) like the Takings Clause of the federal Constitution, Tenn. Const. art. I, 21 encompasses regulatory takings; and (2) the Property Owners’ complaint was sufficient to allege a state constitutional regulatory taking claim, for which they may seek compensation under Tennessee’s inverse condemnation statute. View "Phillips v. Montgomery County" on Justia Law