State of Tennessee v. Antonio Demetrius Adkisson a/k/a Antonio Demetrius Turner Jr., W2022-01009-SC-R11-CD

Seventeen-year-old Adkisson was charged with first-degree murder for the fatal shooting of two victims and later convicted of two counts of second-degree murder after his videotaped statements were admitted at trial. 1
Police responded to the September 26, 2017 shootings, found both victims with multiple gunshot wounds, recovered no weapons, and concluded two firearms were used. 2
Officers contacted Adkisson at home, transported him to the station, and interrogated him overnight while his mother remained in the lobby and was not allowed to join him. 3
During the seven-hour interrogation, investigators falsely implied a video existed, threatened that Adkisson could face the death penalty, and repeatedly refused his requests to speak with his mother. 4
At the juvenile transfer hearing, witnesses placed Adkisson with the co-defendant near the Meadows and supported probable cause for premeditated first-degree murder, leading to transfer to adult court. 5
The trial court denied suppression and the Court of Criminal Appeals affirmed, but a dissent found the confession involuntary and the transfer improper. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juvenile-transfer probable cause review standard 7	Adkisson urged de novo review of probable cause under the transfer statute.	State argued abuse-of-discretion review applied to the entire transfer decision.	Probable cause is reviewed de novo; transfer decision remains abuse-of-discretion. 8
Sufficiency of probable cause for transfer 9	Adkisson claimed the transfer proof did not show he committed premeditated murder.	State said the hearing proof established probable cause.	Probable cause supported transfer; adult prosecution was proper. 10
Validity of Miranda waiver 11	Adkisson said his waiver was uninformed and conditioned on his mother’s presence.	State said he understood and implicitly waived his rights.	He validly waived Miranda rights. 12
Voluntariness of confession 13	Adkisson argued police coercion, including death-penalty threats and denial of his mother, overbore his will.	State said the totality of circumstances showed a voluntary statement.	Confession was involuntary and inadmissible. 14
Disposition 15	Adkisson sought reversal of his convictions.	State sought affirmance.	Convictions vacated and case remanded for further proceedings. 16

Howell v. State, 185 S.W.3d 319 (Tenn. 2006) (juvenile transfer decisions reviewed for abuse of discretion 17)
State v. Strickland, 532 S.W.2d 912 (Tenn. 1975) (juvenile courts have wide discretion in transfer decisions 18)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (probable-cause determinations involve mixed questions reviewed de novo 19)
State v. Bell, 429 S.W.3d 524 (Tenn. 2014) (probable cause is a mixed question of law and fact reviewed de novo 20)
Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty barred for juvenile offenders 21)
State v. Callahan, 979 S.W.2d 577 (Tenn. 1998) (juvenile Miranda waiver evaluated under totality of circumstances and juvenile factors 22)
Moran v. Burbine, 475 U.S. 412 (U.S. 1986) (Miranda waiver must be knowing, intelligent, and voluntary 23)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings to safeguard self-incrimination rights 24)
State v. Climer, 400 S.W.3d 537 (Tenn. 2013) (separates Miranda waiver from due-process voluntariness and applies totality test 25)