Justia Constitutional Law Opinion Summaries

Employee suffered a right shoulder injury while working for Employer. After a benefit review conference in the Department of Labor and Workforce Development ended in an impasse, Employee filed suit for workers' compensation benefits. Prior to trial, Employer requested the appointment of an independent medical examiner pursuant to the medical impairment rating (MIR) process in Tenn. Code. Ann. 50-6-204(d)(5). Because the suit had already been filed, the trial court denied the request and subsequently awarded compensation to Employee. The Supreme Court vacated the judgment and remanded for consideration of the constitutionality of the MIR process. On remand, the trial court concluded (1) section 50-6-204(d)(5), which requires the courts to consider the opinion of an independent medical examiner under that section as presumptively accurate, is an unconstitutional infringement upon the powers of the judiciary; and (2) in the alternative, the statutory presumption was overcome in this case. The Supreme Court reversed in part, holding (1) the MIR process does not violate constitutional principles; and (2) the evidence in this case did not clearly and convincingly rebut the statutory presumption. Remanded. View "Mansell v. Bridgestone Firestone N.A. Tire, LLC" on Justia Law

Defendant was indicted on one count each of driving under the influence, reckless driving, reckless endangerment with a motor vehicle, and violation of the implied consent law. The video recording of the arresting officer's pursuit and stop of Defendant's vehicle was lost before trial. Defendant filed a motion to dismiss the indictment due to the State's alleged failure to preserve potentially exculpatory evidence. Following an evidentiary hearing, the trial court dismissed several of the charges. The court of criminal appeals affirmed. After applying a de novo standard of review, the Supreme Court affirmed, holding (1) based on the record, the trial court did not err by finding it would be fundamentally unfair to require Defendant to go to trial without the video recording; and (2) the trial court did not abuse its discretion in choosing dismissal of several charges as a remedy for the State's loss of the video recording. View "State v. Merriman" on Justia Law

After a jury trial, Defendant was convicted of aggravated statutory rape and sentenced to four years incarceration. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the testimony of the victim, a consenting accomplice in the crime, was not adequately corroborated by other proof. The court of appeals affirmed, holding that the victim qualified as an accomplice to the crime but that her testimony was sufficiently corroborated by the evidence. The Supreme Court affirmed, holding (1) the testimony of a victim of statutory rape does not require corroboration; and (2) the evidence presented at trial, including the victim's testimony, was sufficient to sustain Defendant's conviction. View "State v. Collier" on Justia Law

After a jury trial, Defendant was convicted of false imprisonment and assault and sentenced to concurrent sentences of six months. While Defendant's case was pending on appeal, the Supreme Court filed its opinion in State v. White, which requires trial courts to provide a more specific instruction on kidnapping charges as to whether the removal or confinement of a victim is essentially incidental to any accompanying offense. On appeal, the court of appeals affirmed, holding that although the White instruction was not given at trial, the jury was correctly instructed and the evidence was sufficient to support both convictions. The Supreme Court reversed the conviction for false imprisonment, holding that the omission of the White instruction was not harmless beyond a reasonable doubt. Remanded for a new trial. View "State v. Cecil" on Justia Law

Defendant was arrested on federal and state charges and taken into federal custody. After a trial in federal court, Defendant was convicted. Defendant was subsequently indicted by a Gibson County grand jury on the related state charges. After he was sentenced in federal court, Defendant was transported to Gibson County for an arraignment. Defendant was arraigned and then transferred back into federal custody. Defendant filed a motion to dismiss the state indictment for violations of the Interstate Agreement on Detainers (IAD), articles III and IV. Under article IV, an official of one jurisdiction may seek custody of a prison serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be shuttled back to the original place of imprisonment before the trial. The trial court denied the motion, and Defendant entered a conditional guilty plea. The court of criminal appeals affirmed the trial court's denial of Defendant's motion to dismiss. The Supreme Court reversed, vacated Defendant's conviction, and dismissed the indictment against Defendant with prejudice, holding that article IV of the IAD was violated when Defendant was transferred back to the federal detention center before being tried for the state charges. View "State v. Springer" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and tampering with physical evidence. The court of criminal appeals upheld Defendant's convictions and sentences. Defendant appealed, arguing (1) the trial court erred in declining his request for a jury instruction on defense of a third person, and (2) his abandonment of the murder weapon did not amount to tampering with physical evidence. The Supreme Court (1) affirmed Defendant's conviction for first degree murder, holding that the trial court properly denied Defendant's request for an instruction on defense of a third person; and (2) reversed Defendant's conviction for tampering with physical evidence, holding that Defendant did not "conceal" the murder weapon within the meaning of the relevant statute by tossing the murder weapon over a fence where it could be easily observed and recovered. View "State v. Hawkins" on Justia Law

After a jury trial, Defendant was convicted of first degree premeditated murder and sentenced to life imprisonment. The court of criminal appeals affirmed the conviction and sentence but granted permission to appeal to address whether a discharged alternate juror's communication to the jury foreman entitled Defendant to a new trial. The Supreme Court affirmed, holding (1) the State presented sufficient, admissible evidence to rebut the presumption of prejudice that accompanies an improper outside influence upon the jury, and because there was no reasonable possibility that the note from the discharged alternate juror to the foreman affected the verdict, Defendant was not entitled to relief on this issue; (2) the trial court did not err with respect to the admission of evidence or its jury instructions; and (3) the evidence was sufficient to convict Defendant of first degree premeditated murder. View "State v. Adams" on Justia Law

Plaintiffs filed a claim against a county hospital (Hospital) alleging that the negligence of the hospital and its employees caused the death of their son. The claim was filed fifteen months after Plaintiffs' son's death. Hospital, a governmental entity, filed a motion to dismiss, arguing that the claim was filed outside the one-year statute of limitations of the Governmental Tort Liability Act (GTLA). Plaintiffs argued that their complaint was timely filed because Tenn. Code Ann. 29-26-121(c) extends the GTLA statute of limitations by 120 days. The trial court denied Hospital's motion to dismiss but granted an interlocutory appeal. The court of appeals affirmed the denial of the motion to dismiss. The Supreme Court reversed, holding that the 120-day extension provided by section 29-26-121(c) did not apply to Plaintiffs' claim brought under the GTLA. Remanded for entry of an order dismissing the complaint. View "Cunningham v. Williamson County Hosp. Dist." on Justia Law

A concrete truck collided with a shuttle bus used to transport passengers between an airport and a rental car facility. A passenger who was injured during the collision and his wife filed an action against the bus owner, bus manufacturer, manufacturer of the bus windows, and franchisor of the rental car business. Plaintiffs based their claims in negligence and products liability, arguing that the bus was unsafe because it did not have passenger seatbelts, had windows made of tempered glass, and provided perimeter seating instead of forward-facing rows. A jury found Plaintiffs had sustained damages but assessed 100 percent of the fault to the corporate owner of the concrete truck, which had previously settled with Plaintiffs. On appeal, the court of appeals held that federal law preempted the seatbelt and window-glass claims and ruled that the trial court erred by failing to grant a directed verdict on the perimeter-seating claim. The Supreme Court remanded. On remand, the court of appeals affirmed its prior judgment. The Supreme Court reversed, holding (1) the seatbelt and window-glass claims were not preempted by federal law; and (2) the evidence sufficiently demonstrated causation in fact as to the perimeter-seating claim. Remanded. View "Lake v. The Memphis Landsmen, LLC" on Justia Law

A confidential informant arranged a drug buy from a co-defendant. The co-defendant arrived in his truck with Defendant and another passenger. The three men were arrested, and a consensual search of the truck yielded 153 grams of cocaine and 8.6 grams of marijuana in close proximity to where Defendant had been seated. Police subsequently searched the co-defendant's residence, which yielded 293.5 grams of cocaine and drug paraphernalia. The State consolidated the weight of the cocaine and charged Defendant with possession with intent to sell 300 grams or more of cocaine, among other offenses. The jury convicted Defendant of possession with intent to sell 300 grams or more of cocaine and possession of drug paraphernalia. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was sufficient to support a finding that Defendant constructively possessed the cocaine in the co-defendant's truck, but the evidence was insufficient to support a finding that Defendant constructively possessed the cocaine or drug paraphernalia in the co-defendant's residence; and (2) therefore, the cocaine conviction should be reduced to possession with intent to sell 26 to 299 grams of cocaine and the conviction for possession of drug paraphernalia should be vacated. Remanded for resentencing. View "State v. Robinson" on Justia Law