State of Tennessee v. Billy Hill, E2015-00811-CCA-R3-CD

Background

In 1986 the victim (Defendant's mother) was found stabbed to death; Defendant Billy Hill was the primary suspect but not indicted until 2012; he was convicted of second-degree murder and sentenced to 24 years.
Physical evidence from the 1986 investigation (lockbox and contents, victim’s clothing, hairs/fibers, cassette, knives, etc.) was later lost or destroyed and most items were never analyzed for blood/DNA.
Key prosecution proof consisted of incriminating statements the Defendant allegedly made to two former wives (Wells and Holsinger) and an inmate, Julio Allen, plus scene photos, medical examiner testimony, and witnesses placing the Defendant’s car at the victim’s house.
Defense emphasized prejudice from the 25+ year pre-indictment delay, lost/destroyed evidence, and deceased or faded-witness memories (including a potential alibi witness who later died).
Trial court denied motions to dismiss (lost evidence, due-process/pre-indictment delay, speedy-trial), allowed limited prior-act/domestic-violence testimony as relevant, denied a mistrial after a witness briefly referenced additional violence, declined a requested corroboration jury instruction, and rejected several prosecutorial-misconduct claims.
On appeal the Tennessee Court of Criminal Appeals affirmed conviction but remanded to correct the felony-classification on the judgment (second-degree murder was Class X in 1986).

Issues

Issue	State's (Plaintiff's) Argument	Hill's (Defendant's) Argument	Held
Duty to preserve lost/destroyed evidence (Ferguson test)	Lost items had no apparent exculpatory value; State was negligent but no dismissal required because remaining evidence and testimony sufficed.	Lost evidence (clothing, lockbox, cassette, hairs/fibers) could have yielded DNA/fingerprints implicating others; loss deprived fair trial and required dismissal or relief.	Court: State had a duty to preserve (evidence potentially exculpatory) and was negligent, but balancing Ferguson factors (negligence, significance/substitutes, sufficiency of other evidence) supported denying dismissal; jury was instructed on duty to preserve.
Pre-indictment delay / due process (Gray/Utley/Marion)	Delay was caused by lack of sufficient evidence; indictment followed promptly after new 2011 evidence; State did not seek tactical advantage.	Twenty-six-year delay caused loss of evidence/witnesses and prejudice (including death of alibi witness), violating due process and speedy-trial rights.	Court: Delay raised due-process concern but Defendant failed to show prejudice caused by pre-indictment delay or State intent to gain advantage; claim for Sixth Amendment speedy-trial relief waived.
Admissibility of prior violent acts/domestic abuse (Rule 404(b))	Testimony about abuse was admissible for non-character purposes (motive, context, admissions, explaining witnesses’ delayed disclosure).	Prior-acts testimony impermissibly invited propensity inference and unfair prejudice; some specifics were cumulative or uncorroborated.	Court: Trial court substantially complied with 404(b) procedures; limited, probative testimony (threats, admissions, conduct leading to confession) allowed; overly prejudicial/irrelevant details excluded; no abuse of discretion.
Corroboration requirement for extrajudicial admissions (modified trustworthiness / Bishop)	Extrajudicial admissions were sufficiently corroborated by independent evidence (autopsy, scene photos, lockbox tampering, witness placing car at scene, financial motive), so jury instruction on corroboration unnecessary.	Statements by wives and inmate required a specific corroboration jury instruction; trial court should have instructed jury or suppressed if insufficient corroboration.	Court: Under Bishop modified-trustworthiness test, the court (not jury) determines sufficiency of corroboration; here the court found substantial independent corroboration for Holsinger and Allen (but Wells’ testimony was circumstantial); no instructional error.

Key Cases Cited

State v. Ferguson, 2 S.W.3d 912 (Tenn. 1999) (duty-to-preserve standard and three-factor balancing when evidence is lost or destroyed)
State v. Merriman, 410 S.W.3d 770 (Tenn. 2013) (clarifying preservation obligations and materiality analysis)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial duty to disclose exculpatory evidence)
California v. Trombetta, 467 U.S. 479 (1984) (due-process limits on destruction of potentially exculpatory evidence)
State v. Bishop, 431 S.W.3d 22 (Tenn. 2014) (adopting the modified-trustworthiness corroboration standard for extrajudicial confessions)
Barker v. Wingo, 407 U.S. 514 (1972) (Sixth Amendment speedy-trial balancing test)
United States v. Marion, 404 U.S. 307 (1971) (pre-indictment delay doctrine requiring proof of prejudice and State intent)
Opper v. United States, 348 U.S. 84 (1954) (corroboration principles for confessions)
State v. Gray, 917 S.W.2d 668 (Tenn. 1996) (due-process analysis for pre-indictment delay)