STATE OF TENNESSEE v. JOHN HENRY PRUITT, 2016 Tenn. LEXIS 980

Background

On Oct. 18–19, 2010, John Henry Pruitt shot three people at his home; two victims died and a third was paralyzed; Pruitt was shot and captured by police. He was indicted on two counts of first‑degree premeditated murder, one count attempted premeditated murder, and three aggravated assaults.
Officers executed a search of Pruitt’s residence pursuant to a warrant that contained inconsistent dates (an “Issued on Oct. 18, 2010” line but a magistrate signature dated Oct. 19, 2010); the return was dated Oct. 18.
Evidence seized (including .380 ammunition and a shotgun later recovered from the defendant’s sister) was used at trial; Pruitt moved to suppress based on Rule 41(c) defects.
The trial court denied suppression, applying Tennessee’s 2011 Exclusionary Rule Reform Act (ERRA), Tenn. Code Ann. § 40‑6‑108, treating the date discrepancy as a clerical/good‑faith error.
The Court of Criminal Appeals agreed on conviction/sentencing but held ERRA could not be applied retroactively under Tennessee’s ex post facto analysis (relying on State v. Hayes and Miller v. State). The Tennessee Supreme Court granted review to decide whether Miller should be overruled and whether ERRA’s retroactive application violates the ex post facto clause.
The Supreme Court held Miller was wrongly decided, overruled it, concluded Tennessee’s ex post facto clause has the same scope as the federal clause, and upheld application of ERRA to validate the search warrant; convictions and life‑without‑parole sentences were affirmed.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Pruitt)	Held
Whether ERRA may be applied to validate a warrant issued before ERRA’s enactment	ERRA is procedural; the warrant defect was a clerical/good‑faith mistake within ERRA; statute may be applied to avoid suppression	Retroactive application of ERRA is an ex post facto violation under Tennessee law	ERRA applies; retroactive application is not an ex post facto violation because ERRA is procedural and does not fall within Calder categories
Whether Tennessee’s ex post facto clause provides broader protection than federal clause (Miller)	N/A (State argues federal standard applies)	Miller established a broader, fifth category protecting defendants from laws that alter their situation to their disadvantage	Overruled Miller; Tennessee adopts same ex post facto definition/scope as federal law (limited to Calder categories)
Validity of search warrant under Rule 41(c) and whether evidence should be suppressed	The date discrepancy was a clerical, good‑faith error; ERRA saves admissibility	The warrant failed Rule 41(c) mandatory endorsement requirements; evidence must be suppressed	Court found the discrepancy was a clerical, good‑faith mistake under ERRA §40‑6‑108(c)(1); suppression not required
Sufficiency of evidence for convictions and for sentencing aggravating factor (i)(3)	Evidence (witnesses, ballistics, defendant’s statement) supports convictions and that defendant knowingly created great risk to multiple persons	Self‑defense (true‑man doctrine) and challenges to weighing mitigation	Evidence sufficient for convictions; jury rationally found aggravating circumstance (i)(3); life without parole sentences affirmed

Key Cases Cited

Calder v. Bull, 3 U.S. (3 Dall.) 386 (1798) (articulates the four categories of laws that constitute ex post facto violations)
Collins v. Youngblood, 497 U.S. 37 (1990) (overruled expansive readings of ex post facto law; limits clause to Calder categories)
Miller v. State, 584 S.W.2d 758 (Tenn. 1979) (Tenn. precedent creating a broader fifth category for state ex post facto protection; overruled)
Weaver v. Graham, 450 U.S. 24 (1981) (two‑part test: law must be retrospective and disadvantage the offender)
Peugh v. United States, 569 U.S. 530 (2013) (explains fairness and notice principles underlying ex post facto prohibition)
Carmell v. Texas, 529 U.S. 513 (2000) (clarifies limits on changes to evidentiary rules vis‑à‑vis ex post facto analysis)