State of Tennessee v. John T. Freeland, Jr.
2014 Tenn. LEXIS 640
| Tenn. | 2014Background
- Indicted defendant Freeland and codefendants for murder, kidnapping, and related offenses; State sought death penalty based on multiple aggravating factors.
- Guilt phase: bench trial found Freeland guilty of first degree premeditated murder, felony murder, especially aggravated kidnapping, and tampering with evidence.
- The court merged counts improperly at sentencing; Court of Criminal Appeals noted merger error and this Court remanded for a corrected judgment reflecting single murder conviction.
- Penalty phase: three aggravating circumstances found (i(2), i(6), i(7)); death sentence imposed; additional sentences for kidnapping and tampering were ordered consecutive.
- This Court affirmed conviction and death sentence on automatic review and remanded for corrected merger; separate concurrence addressed proportionality analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Freeland’s confessions were freely and voluntarily made | Freeland argues suppression affirmed error; coercion and involuntariness. | Freeland contends statements not voluntary due to coercion and polygraph promise. | No reversible error; voluntariness and waiver satisfied; statements properly admitted. |
| Whether the death sentence is proportional under mandatory review | State asserts aggravators outweigh mitigators; sentence justified. | Freeland argues sentence may be disproportionate; Bland framework used for comparison. | Death sentence not disproportionate; proportionality upheld. |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 ((U.S. 1966)) (requirement to warn and obtain valid waiver before custodial interrogation)
- State v. Climer, 400 S.W.3d 537 ((Tenn. 2013)) (totality-of-circumstances test for knowing and voluntary waiver and voluntariness of confessions)
- State v. Bland, 958 S.W.2d 651 ((Tenn. 1997)) (proportionality review scope for death penalty cases ( Bland approach))
- State v. Pruitt, 415 S.W.3d 180 ((Tenn. 2013)) (reaffirmed Bland-based proportionality framework (concurring dissent in original))
- Jackson v. Virginia, 443 U.S. 307 ((U.S. 1979)) (sufficiency standard: rational trier of fact could convict)
- Wagner v. State, 382 S.W.3d 289 ((Tenn. 2012)) (corpus delicti corroboration rule for confessions (addressed))
- State v. Cribbs, 967 S.W.2d 773 ((Tenn. 1998)) (merger of convictions where one murder occurred)