State of Tennessee v. Prince Adams, 2013 Tenn. LEXIS 442

Adams killed Ohrdra Flowers with a pocketknife after Ambien use, and disposed of the body near Cromwell Elementary School.
Police investigations revealed inconsistencies in Adams's statements and a recorded admission to killing the victim.
Trial court discharged two alternates prior to deliberations; a discharged alternate left a note to the foreman asserting guilt-related views.
Foreman testified the note did not affect deliberations; the State sought to rebut prejudice under Rule 606(b).
Court of Criminal Appeals affirmed; Tennessee Supreme Court addressed whether the alternate-juror note created extraneous prejudice and if the State rebutted it; held no reversible error.
Court affirmed conviction for first degree premeditated murder and denied relief on other evidentiary issues, noting harmless error in the foreman’s testimony and upholding admissibility of photographs and audiotape.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror misconduct and prejudice presumption	Adams: note from discharged alternate juror tainted verdict; presumption of prejudice applies.	State: no substantial effect; prejudice rebutted by evidence.	Presumption rebutted; no reasonable possibility note affected verdict; harmless error.
Admission of life-with-victim photograph	Adams: portrait photograph irrelevant and prejudicial.	State: photographs relevant to existence and injuries; probative value outweighs prejudice.	Admission of life photograph deemed error but harmless; no new trial required.
Admission of audiotape containing prior domestic-violence reference	Adams: 404(b) prior act improper to prove propensity.	State: tape shows state of mind and motive; procedural 404(b) satisfied.	No abuse of discretion; probative value outweighed prejudice given context.
Special jury instruction on diminished capacity	Request for explicit diminished capacity instruction should have been given.	Charge adequately addressed ability to form culpable mental state.	No error; general instruction allowed consideration of Ambien evidence.
Sufficiency of the evidence on premeditation	Evidence insufficient to prove premeditated murder.	Sufficient to prove premeditation based on threats, multiple stab wounds, and weapon use.	Evidence sufficient to support first degree murder.

State v. Walsh, 166 S.W.3d 641 (Tenn. 2005) (prohibits juror testimony about the effect of extraneous information in Rule 606(b) proceedings; permits limited rebuttal evidence.)
Remmer v. United States, 347 U.S. 227 (U.S. 1954) (outside influence; non-juror communications with the jury.)
State v. Bobo, 814 S.W.2d 353 (Tenn. 1991) (alternate juror misconduct; timing of deliberations.)
Caldararo ex rel. Caldararo v. Vanderbilt Univ., 794 S.W.2d 738 (Tenn. Ct. App. 1990) (principles underpinning Rule 606(b) admissibility.)
Banks v. State, 564 S.W.2d 947 (Tenn. 1978) (photograph evidence and prejudice considerations.)
Dicks v. State, 615 S.W.2d 126 (Tenn. 1981) (photographs of victim; probative value vs. prejudice.)
Nesbit v. State, 978 S.W.2d 872 (Tenn. 1998) (photographic evidence; relevance and prejudice.)
Dorantes v. State, 331 S.W.3d 370 (Tenn. 2011) (circumstantial vs. direct evidence standard of review.)
Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (sufficiency review standard; circumstantial evidence permitted.)