State of Tennessee v. Charles Beaty
W2015-00223-CCA-R3-CD
| Tenn. Crim. App. | Aug 16, 2016Background
- Victim (a minor when she first reported) disclosed alleged child rape in Feb 2012; defendant indicted (case 13-00596) Feb 2013 for rape between May–Sept 2006.
- Defendant moved to dismiss alleging pre-accusation delay and inability to locate witnesses; trial court denied the motion in Nov 2013.
- On June 16, 2014 (trial day) victim’s recollection changed (alleged age at offense and timeframe); trial court dismissed the 2013 indictment (record language and judgment referred to a speedy-trial violation).
- State reindicted next day (case 14-02907) adding overlapping and broader date ranges and an aggravated-sexual-battery count.
- Trial court later dismissed the second indictment with prejudice (citing speedy-trial and due-process concerns). State appealed only the dismissal of the second indictment.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Beaty) | Held |
|---|---|---|---|
| Validity of reindictment after initial dismissal | Initial dismissal was without prejudice (Rule 48(b)), so reindictment is permitted | Initial dismissal was constitutional (speedy-trial) and thereby barred reindictment | Trial court’s oral/written dismissal was constitutional in nature; State could not reindict as to offenses identical to those already dismissed — those must be dismissed on remand |
| Speedy-trial violation as to charges in second indictment | Delay between second indictment and dismissal (~6–7 months) not long enough to trigger Sixth Amendment inquiry; most delay caused by victim’s late reporting and memory change | Delay and pretrial incarceration violated speedy-trial rights | Dismissal of the second indictment on Sixth Amendment speedy-trial grounds was erroneous — post-indictment delay did not approach the presumptive one-year threshold, so Sixth Amendment not implicated |
| Due-process claim for pre-indictment delay as to new charges | No proof State intentionally delayed or that defendant suffered actual, particularized prejudice | Pre-indictment delay (7–12 years) impaired defense; witnesses died/unlocatable | Court reversed dismissal for due-process grounds: defendant failed to show actual prejudice or State tactical delay; most delay attributable to victim’s late reporting and memory change |
| Remedy/Remand instructions | Allow prosecution on new offenses not identical to dismissed charge | Bar any prosecution on previously dismissed conduct | Remanded to determine which counts in the second indictment duplicate the previously dismissed offense (those must be dismissed); reversed dismissal as to genuinely new charges so prosecution may proceed on them |
Key Cases Cited
- State v. Benn, 713 S.W.2d 308 (Tenn. 1986) (Rule 48(b) dismissal without prejudice normally permits reindictment; dismissal with prejudice bars reprosecution)
- State v. Simmons, 54 S.W.3d 755 (Tenn. 2001) (Sixth Amendment speedy-trial analysis applies only to post-accusation delay)
- State v. Utley, 956 S.W.2d 489 (Tenn. 1997) (due-process standard for pre-indictment delay: actual prejudice and deliberate delay for tactical advantage)
- State v. Gray, 917 S.W.2d 668 (Tenn. 1996) (when State had no knowledge of offense, courts evaluate length, reason, and degree of prejudice for due-process claims)
- State v. Carico, 968 S.W.2d 280 (Tenn. 1998) (multi-year pre-accusation delay involving child-victim claims requires careful review but is not per se "profoundly excessive")
- Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor Barker test for speedy-trial claims)
- Doggett v. United States, 505 U.S. 647 (U.S. 1992) (presumptive prejudice from excessive delay can satisfy speedy-trial analysis)