State of Tennessee v. Charles Edgar Ledford
2014 Tenn. Crim. App. LEXIS 20
| Tenn. Crim. App. | 2014Background
- Ledford pled guilty to multiple sex offenses including two counts of sexual exploitation of a minor, child neglect, two counts of aggravated sexual battery, and two counts of rape of a child, with an effective 56-year sentence.
- Convictions arose from materials discovered in Ledford's Oakland Road house in Sweetwater, which the City condemned for demolition after hazardous conditions were found.
- City inspectors conducted administrative warrants, condemned the property, and eventually demolished the house; contraband (child pornography) was found in plain view during environmental testing and later at demolition.
- Investigators obtained four search warrants to view and seize the seized materials; Ledford denied consent to view the videos, but the state proceeded with warrants and multiple seizures.
- Ledford challenged the suppression of evidence via certified questions of law; the trial court denied suppression, and the issue was preserved for direct appeal under Rule 37(b).
- The Court held some convictions (12092, 12091) were not dispositive; for the remaining conviction, the Court found Ledford had no reasonable expectation of privacy due to abandonment, leading to suppression of certain counts but affirmation of others (including two counts of rape and two counts of aggravated sexual battery) arising from the same materials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial discovery without a warrant was suppressible | Ledford | Ledford | No suppression; abandonment doctrine applied |
| Whether the search and recovery without a warrant was lawful | Ledford | Ledford | Lawful due to abandonment; no Fourth Amendment violation |
| Whether the warrant affidavit for viewing seized evidence established probable cause | Ledford | Ledford | Pretermitted; third question resolved by abandonment ruling |
| Whether Ledford had a legitimate expectation of privacy in the Oakland Road house and its contents | Ledford | Ledford | Ledford abandoned the property; no reasonable expectation of privacy |
| Whether the certified questions were dispositive of the case | State and Defendant agreed they were dispositive | Ledford | Questions dispositive for 12064 counts; others dismissed |
Key Cases Cited
- State v. Binette, 33 S.W.3d 215 (Tenn. 2000) (trial-court findings must be upheld unless preponderated by evidence)
- State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (credibility and weight for suppression rulings reviewed deferentially)
- Katz v. United States, 389 U.S. 347 (1967) (establishes reasonable-expectation-of-privacy doctrine)
- Oliver v. United States, 466 U.S. 170 (1984) (property interests do not control Fourth Amendment rights)
- Katz v. United States, 389 U.S. 347 (1967) (privacy expectation governs searches; not positions)
- California v. Greenwood, 486 U.S. 35 (1988) (abandoned property in private hands may be seized)
- United States v. Fulani, 368 F.3d 351 (3d Cir. 2004) (abandonment analysis in Fourth Amendment contexts)
- Walter v. United States, 447 U.S. 649 (1980) (private-party search limits on subsequent government viewing)