Consistently applies controlling U.S. Supreme Court decisions without questioning them, e.g., following Powers on Batson standing [1] and Boykin/Neal on guilty-plea voluntariness [5]. State v. Ellison ↗ Blankenship v. State ↗
In State v. Washington, a defendant with no prior record who was a long-time schoolteacher was charged with DUI along with simple possession of marijuana and cocaine, unlawful possession of drug paraphernalia, and unlawful possession of a firearm after an arrest on Christmas Eve. The district attorney denied her application for pretrial diversion on all charges based on a statute barring diversion for DUI offenses, and both the trial court and Court of Criminal Appeals upheld that denial. The Tennessee Supreme Court held that the statutory bar applies only to the DUI charge itself and does not extend to the other charges, even though they arose from the same incident and would normally be joined under criminal procedure rules. The court reasoned that the legislature intended only to protect mandatory minimum DUI sentences from suspension or diversion, with no indication of broader intent, and that criminal statutes must be construed narrowly in the defendant's favor. It therefore vacated the denial and remanded for severance of the DUI charge, entry of a plea on that offense, and consideration of diversion on the remaining charges.
In State v. Stamper, the defendant was convicted of delivering cocaine and conspiring to sell it based in part on statements by an alleged co-conspirator admitted under Tennessee Rule of Evidence 803(1.2)(E). The Court of Criminal Appeals reversed both convictions, holding that the conspiracy was not proven beyond a reasonable doubt and that the statements should therefore have been excluded as hearsay. The Tennessee Supreme Court reversed, ruling that the existence of a conspiracy for purposes of admitting co-conspirator statements need only be shown by a preponderance of the evidence, consistent with federal precedent such as Bourjaily v. United States and analogous evidentiary standards for other preliminary facts. The court found the trial evidence sufficient under that standard and remanded for reconsideration of the convictions with the statements included. The opinion addresses criminal law and procedure.
The case involved a police officer who responded to two urgent anonymous reports of a man with a shotgun threatening to shoot someone in a trailer park. The officer located the defendant in a nearby yellow Ford, activated his blue lights to stop the moving vehicle, observed a shotgun inside, and arrested him on multiple charges including possession of a weapon with intent to go armed. The trial court suppressed the evidence, finding no reasonable suspicion for the stop, and the Court of Criminal Appeals affirmed. The Tennessee Supreme Court reversed, holding that the stop was reasonable under the Fourth Amendment and the state constitution because the tips, combined with the threat of imminent violence and partial corroboration, provided specific and articulable facts justifying a brief investigatory seizure under Terry v. Ohio standards. The case was remanded for further proceedings.
In Blankenship v. State, the petitioner filed a post-conviction challenge to the validity of six prior guilty pleas used to establish his habitual criminal status and life sentence, claiming the pleas were not voluntary and intelligent under Boykin v. Alabama because he had not been advised of his right against self-incrimination or that the convictions could enhance future sentences. The Tennessee Supreme Court granted review to address the application of Boykin standards in a collateral attack far removed from the original convictions, in light of the U.S. Supreme Court's decision in Parke v. Raley. The court held that on collateral review, final convictions carry a presumption of regularity, and the unavailability of transcripts does not require the state to prove validity through extra-record evidence or create a silent-record violation under Boykin. It distinguished this collateral context from direct appeals and noted that certain state-law advisements on enhancement were not required by federal constitutional standards at the time of the pleas.
In Hawk v. Hawk, married parents denied visitation to the paternal grandparents amid family conflicts over child-rearing, discipline, and associations. The grandparents sought court-ordered visitation under T.C.A. § 36-6-301, which allows reasonable grandparent visitation if in the child's best interests. The trial court and Court of Appeals granted extensive visitation despite finding the parents fit, but the Tennessee Supreme Court reversed. The court held that applying the statute to these facts violated the parents' constitutional right to privacy in parenting decisions under Article I, Section 8 of the Tennessee Constitution, because fit parents have a fundamental liberty interest in controlling their children's upbringing and associations, and the state interest in best interests alone is not sufficiently compelling to override it without a showing of harm.
The case involved Danny Branam's convictions for conspiracy to commit armed robbery, armed robbery, and first-degree felony murder, along with his death sentence for the murder, stemming from a 1987 shooting during a robbery in Knoxville. The Tennessee Supreme Court reduced Branam's death sentence to life imprisonment, concluding that as a non-triggerman accomplice he lacked the reckless indifference to human life required under the Eighth Amendment and state law for capital punishment in felony-murder cases, and that the sentence was disproportionate compared to similar cases. The court remanded for a hearing on a potential Brady violation regarding withheld evidence but found the defendant's confession obtained via a jail informant admissible and upheld the convictions against other challenges, including issues with counsel withdrawal and jury voir dire. The opinion addressed the adequacy of the record on severance and attorney conflicts but found no reversible error warranting a new trial absent the Brady issue.
