State of Tennessee v. Charles Raymond Locke, Jr., E2025-00507-CCA-R3-CD

Background

A Knox County jury convicted Locke of second degree murder for the death of his domestic partner, and the trial court imposed a twenty-five-year sentence. 1
The victim had suffered longstanding abuse, and shortly before her death Locke threatened, “I just ought to go kill that whore.” 2
Locke moved to suppress his custodial statement to Detective Ryan, arguing he did not knowingly and voluntarily waive his Miranda rights. 3
At the suppression hearing, Detective Ryan testified Locke agreed to talk, appeared eager and cooperative, was not intoxicated or injured, and signed the waiver after further explanation when he said he understood it “a little bit.” 4
At trial, witnesses described Locke’s violence, the victim’s vulnerable physical condition, and the chaotic scene when officers found her severely injured in the bathroom. 5
The medical examiner concluded the victim died from multiple blunt-force injuries and strangulation, and the jury convicted Locke before the court imposed the maximum-range sentence. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Locke’s Miranda waiver voluntary and knowing? 7	Locke argued his waiver was not knowing or voluntary.	The State argued Ryan fully explained the rights and Locke waived them freely.	Yes; the waiver was valid and the statement was admissible. 8
Did the court abuse its discretion by imposing twenty-five years? 9	Locke argued factor (5) was wrongly applied and the sentence was excessive.	The State argued the within-range sentence was properly supported.	No; the twenty-five-year sentence was affirmed. 10

Key Cases Cited

State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (suppression-hearing factual findings are upheld unless the evidence preponderates otherwise 11)
State v. Carter, 16 S.W.3d 762 (Tenn. 2000) (prevailing party gets strongest legitimate view of the evidence on suppression review 12)
State v. Walton, 41 S.W.3d 75 (Tenn. 2001) (suppression-law application is reviewed de novo 13)
State v. Crutcher, 989 S.W.2d 295 (Tenn. 1999) (suppression-law application is reviewed de novo 14)
State v. Henning, 975 S.W.2d 290 (Tenn. 1998) (appellate court may consider proof from both suppression hearing and trial 15)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial statements are inadmissible absent advisement and waiver of rights 16)
State v. Phillips, 30 S.W.3d 372 (Tenn. Crim. App. 2000) (involuntary confessions produced by coercion are inadmissible 17)
State v. Huddleston, 924 S.W.2d 666 (Tenn. 1996) (lists totality-of-the-circumstances factors for voluntariness 18)
State v. Blackstock, 19 S.W.3d 200 (Tenn. 2000) (no single voluntariness factor is determinative 19)
State v. Keen, 926 S.W.2d 727 (Tenn. 1994) (knowing-and-voluntary confession findings bind appellate courts absent contrary evidence 20)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (defendant bears burden of establishing sentence impropriety 21)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (sentences within range are reviewed for abuse of discretion with a presumption of reasonableness 22)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (reaffirms Bise sentencing review 23)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (enhancement and mitigation weighing is committed to trial-court discretion 24)
State v. Poole, 945 S.W.2d 93 (Tenn. 1997) (exceptional cruelty may be supported by conduct separate from the offense itself 25)