Eddie Medlock v. State of Tennessee
W2015-02130-CCA-R3-PC
| Tenn. Crim. App. | Oct 21, 2016Background
- Eddie Medlock was convicted by a jury of two counts of aggravated rape and two counts of especially aggravated kidnapping for a brutal assault on his ex-girlfriend involving a heated coat hanger; one kidnapping count was later vacated on direct appeal.
- Post-conviction petition was filed June 27, 2003 alleging, principally, ineffective assistance of counsel and requesting funding for independent DNA/expert testing; proceedings were delayed and a hearing began in August 2015.
- In 2005 TBI testing of the forensic swabs was inconclusive; Medlock sought state-funded independent testing which the post-conviction court denied; interlocutory appeals were denied.
- In 2015 upgraded TBI testing produced a usable DNA profile from the sperm fraction identifying Medlock as the major contributor. The post-conviction court nevertheless denied relief on all claims.
- The post-conviction court found trial counsel’s strategic decisions (not to test earlier, limited meetings, cross-examination that opened prior-bad-act testimony, and not seeking certain lesser-included instructions) were not deficient or, in any event, caused no prejudice given overwhelming evidence. The Court of Criminal Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether post-conviction court erred by denying funding for independent DNA/expert testing | Medlock: denial deprived him of testing that might have been exculpatory and violated due process/equal protection because capital petitioners may get funding | State: rules/precedent disallow funding for non-capital post-conviction experts; moreover TBI later performed more sensitive testing in 2015 producing Medlock's profile | Moot: 2015 TBI testing produced the DNA profile the petitioner sought; Davis/Owens precedent & Post-Conviction DNA Act govern and petitioner waived statutory findings; no relief due |
| Ineffective assistance for failing to obtain DNA testing at trial | Medlock: counsel was deficient for not forcing testing which might have shown another perpetrator | State: testing in 2005 would likely have been impossible or inculpatory; strategic decision to avoid testing was reasonable | Denied: no deficiency or prejudice — later testing confirmed inculpatory result and trial strategy was reasonable |
| Failure to request lesser-included offense instructions (sexual battery, aggravated sexual battery) | Medlock: counsel and appellate counsel were ineffective for not obtaining/raising instructions | State: jury was instructed on rape (an intervening lesser) and evidence overwhelmingly proved penetration; trial theory contested ID, not degree | Denied: no prejudice — jury rejected intervening lesser (rape) and evidence overwhelmingly supported aggravated rape over lesser offenses |
| Counsel’s preparation and cross-examination that opened door to prior-bad-act testimony | Medlock: insufficient meetings/communication and poor cross led to admission of prior assaults damaging defense | State: meetings were adequate; cross-examination was strategic to suggest third-party perpetrator; prior-act evidence would not change outcome | Denied: strategic choices reasonable; petitioner failed to show how more preparation or different cross would have produced a different outcome |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective assistance test) (deficiency and prejudice standard)
- Davis v. State, 912 S.W.2d 689 (Tenn. 1995) (no constitutional right to state-funded expert services in non-capital post-conviction proceedings)
- Owens v. State, 908 S.W.2d 923 (Tenn. 1995) (statutory entitlement to expert assistance in some capital post-conviction cases)
- Moore v. State, 485 S.W.3d 411 (Tenn. 2016) (prejudice analysis for failure to instruct on lesser-included offenses)
- Williams v. State, 977 S.W.2d 101 (Tenn. 1998) (harmlessness when jury convicts of greater offense after being charged on intervening lesser)
- Ward v. State, 315 S.W.3d 461 (Tenn. 2010) (post-conviction burden and standard of review)
- Grindstaff v. State, 297 S.W.3d 208 (Tenn. 2009) (clear and convincing evidence standard in post-conviction)
- Honeycutt v. State, 54 S.W.3d 762 (Tenn. 2001) (credibility and factual-findings deference on appeal)
- McIntyre v. Traughber, 884 S.W.2d 134 (Tenn. Ct. App. 1994) (mootness / justiciability doctrine)