State of Tennessee v. Charlotte Lynn Frazier And Andrea Parks
558 S.W.3d 145
Tenn.2018Background
- In 2015, a multi-jurisdictional drug investigation used wiretaps and led agents from the 23rd Judicial District to seek search warrants for residences in the 19th Judicial District (Montgomery and Robertson Counties).
- A 23rd Judicial District circuit court judge (who had issued the wiretap orders) signed search warrants for the two defendants’ homes located in the 19th Judicial District. Seized evidence included large quantities of methamphetamine, cash, drugs, weapons, and phones.
- Defendants moved to suppress the evidence, arguing the issuing judge lacked geographic jurisdiction to sign warrants for property outside his statutorily assigned judicial district; Rule 41(a) requires a magistrate with jurisdiction in the county where the property is located.
- Trial court granted suppression; Court of Criminal Appeals affirmed. The State appealed to the Tennessee Supreme Court raising (1) whether circuit court judges acting as magistrates may issue warrants for property outside their district and (2) whether a good-faith exception applies.
- The Tennessee Supreme Court held that, absent interchange, designation, appointment, or other lawful means, a circuit court judge lacks authority to issue search warrants for property outside his statutorily assigned judicial district; the warrants were therefore invalid and suppression was affirmed. The Court also declined to apply the Reynolds/Davidson good-faith exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether circuit court judges acting as magistrates may issue search warrants for property outside their assigned judicial district | Section 40-1-106 ("judges ... throughout the state") grants statewide magistrate authority to issue warrants | Statutes dividing the State into judicial districts and provisions on interchange/appointment limit judges to their assigned district absent interchange/appointment/designation | Circuit judges lack authority to issue warrants outside their statutorily assigned district without interchange/appointment/designation; warrants invalid |
| Whether Tennessee Rule of Criminal Procedure 41(a) permits out-of-district warrants when signed by a circuit judge | State: Rule 41 and §40-1-106 allow circuit judges to act as magistrates "throughout the state" | Defendants: Rule 41 requires a magistrate with jurisdiction in the county where property is located, so out-of-district warrants are improper | Rule 41, read with statutes defining judicial districts and interchange rules, does not permit such out-of-district warrants absent lawful conferral of jurisdiction |
| Whether the good-faith exception saves evidence seized under these warrants | State: Officers reasonably relied on practice/authority (citing AG opinion and federal district court decisions); good-faith exception should apply | Defendants: The judge lacked jurisdiction; the warrants were void ab initio and cannot be cured by good-faith reliance | Tennessee’s narrow Reynolds good-faith exception does not apply; the Court declines to extend it to warrants void for lack of judicial geographic jurisdiction |
| Whether §40-1-106 should be read to expand geographic jurisdiction of circuit judges when acting as magistrates | State: Phrase "throughout the state" expands magistrate authority statewide | Defendants: Phrase merely lists offices that exist throughout the state and does not alter separate statutes that confine judicial district jurisdiction | Court: §40-1-106 does not expand geographic jurisdiction; it lists officers "throughout the state" who may be magistrates but does not override district-based jurisdiction statutes |
Key Cases Cited
- State v. Reynolds, 504 S.W.3d 283 (Tenn. 2016) (adopted narrow good-faith exception limited to objectively reasonable reliance on binding appellate precedent)
- State v. Davidson, 509 S.W.3d 156 (Tenn. 2016) (applied good-faith analysis to inadvertent/technical Rule 41 error)
- State v. Lowe, 552 S.W.3d 842 (Tenn. 2018) (held statutory good-faith exception unconstitutional)
- Shadwick v. City of Tampa, 407 U.S. 345 (U.S. 1972) (discusses role and qualifications of magistrates in issuing warrants)
- Davis v. United States, 564 U.S. 229 (U.S. 2011) (Supreme Court good-faith exception precedent considered in Reynolds)
- United States v. Master, 614 F.3d 236 (6th Cir. 2010) (discussed interplay of state law and magistrate qualifications and geographic limits on warrant authority)