State of Tennessee v. Raffell Griffin, 610 S.W.3d 752

Kyle A. Hixson served as Deputy District Attorney General for Knox County when the grand jury indicted the defendants; he was later appointed and sworn in as a Knox County Criminal Court judge and assigned to these cases.
Defendants were indicted on serious charges (RICO, drug offenses, firearm enhancements, and murder for one defendant).
Defendants moved to recuse Judge Hixson, arguing his prior supervisory role (as described in his judicial application and campaign website) created an appearance of partiality because his office supervised grand-jury and charging processes.
Judge Hixson denied recusal, finding he had no direct or supervisory involvement in these specific prosecutions; ADA TaKisha Fitzgerald corroborated that he had not worked on or discussed the cases.
The Court of Criminal Appeals reversed, concluding the judge’s application/website statements created an objectively reasonable question as to impartiality; the State sought accelerated review.
The Tennessee Supreme Court granted review, applied the objective recusal standard, credited the trial judge’s uncontested factual explanation of noninvolvement, and reversed the Court of Criminal Appeals, reinstating the trial judge’s denial of recusal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Hixson must recuse because he previously served as Deputy DA with supervisory authority when these indictments were returned	Hixson’s judicial application and campaign materials portray him as supervising all Knox County prosecutions and reviewing cases bound for the grand jury, creating an appearance of partiality	Hixson and the State: he had no personal or direct supervisory involvement in these particular prosecutions; ADA Fitzgerald confirmed he never worked on or discussed the cases	Recusal not required: under the objective test, knowing all facts known to the judge (including no direct involvement), a person of ordinary prudence would not reasonably question his impartiality
Whether the trial judge applied a subjective rather than the required objective standard (and whether appellate court correctly reversed)	Defendants: judge relied on his subjective belief rather than the objective standard, so recusal should follow	State: judge applied facts known to him and the objective standard; CCA erred	Tennessee Supreme Court: CCA erred; judge’s factual findings were credible and evaluated under the objective standard; reversal of trial judge was improper

Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (articulates objective test for appearance of partiality)
State v. Cannon, 254 S.W.3d 287 (Tenn. 2008) (appearance-of-bias recusal is an objective inquiry)
Davis v. Liberty Mut. Ins. Co., 38 S.W.3d 560 (Tenn. 2001) (standard for reasonable basis to question impartiality)
Owens v. State, 13 S.W.3d 742 (Tenn. Crim. App. 1999) (mere employment in prosecutor’s office, without direct involvement, does not mandate recusal)
Smith v. State, 357 S.W.3d 322 (Tenn. 2011) (recusal required where judge-prosecutor had prosecuted related matters and regularly communicated with prosecutors)
Williams v. Pennsylvania, 136 S. Ct. 1899 (2016) (recusal required where prior prosecutorial decisions showed meaningful personal involvement)