State of Tennessee v. Lisa Kay Young, M2016-01149-CCA-R3-CD

Victim Jill Farley was murdered on Feb. 9, 2014; surveillance and witness evidence placed a white Toyota and a dark minivan at the Dollar General around the time of the killing.
Miranda Brown and Brian Logan were arrested the day after the murder; Lisa Kay Young (Defendant) was arrested ~11 months later after investigators tied text messages from a phone ending in 8572 to the victim’s phone.
Phone records showed texts between 8572 (registered to Young) and the victim; the State relied on those messages as key evidence linking Young to arranging the meeting.
At a pretrial hearing, Brown invoked the Fifth Amendment; the trial court found her unavailable and excluded portions of her recorded police statements as inadmissible hearsay (not statements against penal interest).
At trial the jury convicted Young of first-degree premeditated murder, second-degree murder (lesser-included), and aggravated assault; Young appealed, arguing (1) exclusion of Brown’s statements was error and (2) the lesser convictions should merge into the first-degree murder conviction.
The Court of Criminal Appeals held the trial court erred in excluding Brown’s statements under Tenn. R. Evid. 804(b)(3), found the error not harmless, reversed and remanded for a new trial, and ordered the lesser convictions to merge into the first-degree murder conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Miranda Brown’s out-of-court statements under Tenn. R. Evid. 804(b)(3) (statements against interest)	State argued the exclusion claim was waived for failure to include full transcript and that Brown’s statements were not sufficiently against interest and posed confrontation/cross‑examination problems	Young argued Brown’s police statements admitting she used Young’s phone, pretended to be Young, and that Young was not involved were admissible as statements against penal interest and critical exculpatory evidence	Court held the trial court erred: individual portions of Brown’s statements (possession/use of Young’s phone, pretending to be Young, knowledge of text content, and denying Young’s involvement) were statements against interest under 804(b)(3); exclusion was prejudicial and not harmless, warranting a new trial
Double jeopardy / merger of convictions (second-degree murder and aggravated assault with first-degree murder)	State asked merger to avoid double jeopardy implications but did not seek vacatur of the lesser verdicts	Young argued the lesser convictions must be vacated or merged to avoid multiple punishments for the same killing	Court held the convictions for second-degree murder and aggravated assault should merge into the first-degree murder conviction to avoid double jeopardy

Williamson v. United States, 512 U.S. 594 (U.S. 1994) (principle that components of a declarant’s broader statement must be examined individually for self‑inculpatory quality)
State v. Dotson, 254 S.W.3d 378 (Tenn. 2008) (requirement to analyze each portion of a declarant’s statement when assessing declarant‑against‑interest admissibility)
State v. Berry, 503 S.W.3d 360 (Tenn. 2015) (merger principles when convictions are lesser‑included or alternative theories)
State v. Howard, 504 S.W.3d 260 (Tenn. 2016) (framework for determining lesser‑included offenses)
State v. Kiser, 284 S.W.3d 227 (Tenn. 2009) (one murder conviction for a single victim rule)
State v. Rodriguez, 254 S.W.3d 361 (Tenn. 2008) (harmless‑error analysis for nonconstitutional trial errors)
Osborne v. Commonwealth, 43 S.W.3d 234 (Ky. 2001) (caution that statements against interest may mix reliable and self‑serving material; examine parts separately)