State of Tennessee v. Jeffrey Scott Long, E2015-01287-CCA-R3-CD

Background

Defendant Jeffrey Scott Long was tried for first-degree murder (including felony murder), aggravated burglary, and aggravated assault in connection with the September 2009 death of Janice Long; convictions were returned and the court imposed a life sentence for murder and concurrent six-year terms on other counts.
Police found the victim dead in her apartment from multiple blunt and sharp-force injuries and strangulation; a hammer and chisel at the scene tested positive for the victim’s blood.
Defendant was seen near the victim’s apartment that night on surveillance video, was later found at his motel apartment with blood on him and an apparent suicide note and photo of the victim, and was hospitalized then interviewed by police after signing a Miranda waiver.
Pretrial: Defendant moved to suppress his statement (claiming an unequivocal request for counsel and involuntary waiver), to suppress evidence from a warrantless entry of his apartment, and to exclude autopsy/crime-scene photos and an order of protection; the trial court denied suppression and admitted much of the contested evidence with redactions.
At trial the medical examiner testified about extensive blunt- and sharp-force injuries and strangulation; DNA/serology linked clothing and weapons to the victim; Defendant gave a detailed inculpatory statement claiming a fight and that he did not intend to kill her.
The Court of Criminal Appeals affirmed, rejecting suppression and other evidentiary and instructional claims and finding the evidence sufficient to sustain convictions.

Issues

Issue	State's Argument	Long's Argument	Held
Whether Defendant’s custodial statement should be suppressed because he unequivocally requested counsel / did not validly waive Miranda	Waiver was knowing/voluntary; request for counsel was equivocal and detectives repeatedly advised he could stop or request counsel	Defendant said he needed an attorney and thus unequivocally invoked the right; waiver was not knowing/voluntary given officer statements	Waiver valid; request equivocal (wanted counsel later but affirmed desire to talk); statement admitted
Whether admission of the victim’s 2009 order of protection violated rules on prior bad-acts evidence	Order was relevant to elements (aggravated assault by violating order) and to motive, intent, premeditation; probative value outweighed prejudice	Order and clerk’s description were unfairly prejudicial and not proved by clear and convincing evidence	Admitted under Rule 404(b) principles; trial court found relevancy and clear-and-convincing proof; no abuse of discretion
Whether autopsy and crime-scene photos/video were inadmissible (unduly prejudicial)	Photos/videos relevant to explain injuries, show struggle/location, and aid medical testimony; court redacted/graduated exhibits	Photographs are gruesome and prejudicial; some exhibits unnecessary	Trial court balanced Fed. R. Evid. 403 factors, redacted/ excluded certain photos; admission not an abuse of discretion
Whether warrantless entry/search of Defendant’s apartment required suppression	Entry was justified by exigent circumstances (Defendant in doorway, bleeding, severe wound) and plain-view evidence; additionally inevitable discovery supported later seizures despite a defective warrant	Entry/search was warrantless and seizure unlawful; subsequent warrant defective; evidence should have been suppressed	Warrantless entry for rendering aid was reasonable exigency; plain-view and inevitable-discovery rulings supported admission; no suppression warranted
Whether the medical examiner exceeded her expertise by testifying about blood-spatter implications	ME appropriately limited testimony to anatomical sources of blood and how injuries correlate with scene patterns; she avoided specialized spatter measurements	ME improperly opined on blood-spatter direction/angles beyond her qualifications	Court found gatekeeper inquiry satisfied; testimony stayed within acceptable bounds for her expertise
Whether the evidence was insufficient to support convictions	State: combined physical, DNA, admissions, location, prior order and motive permitted inference of premeditation and felony-murder	Long: denied premeditation and claimed self-defense/attack by victim	Evidence (forensic, eyewitness, surveillance, defendant’s own statement) was sufficient for first-degree murder (premeditation) and felony murder during aggravated burglary

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings and custodial interrogation rules)
Edwards v. Arizona, 451 U.S. 477 (1981) (unequivocal request for counsel ends interrogation)
Moran v. Burbine, 475 U.S. 412 (1986) (knowing and voluntary waiver standard)
Berghuis v. Thompkins, 560 U.S. 370 (2010) (silence and waiver analysis)
Gerstein v. Pugh, 420 U.S. 103 (1975) (prompt judicial determination of probable cause requirement)
County of Riverside v. McLaughlin, 500 U.S. 44 (1991) (48-hour rule for probable-cause determinations)
Nix v. Williams, 467 U.S. 431 (1984) (inevitable discovery doctrine)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency-of-the-evidence standard)
Mincey v. Arizona, 437 U.S. 385 (1978) (exigent-circumstances exception to warrant requirement)