M2024-01446-CCA-R3-CD
Tenn. Crim. App.Jul 21, 2026Background
- Jenkins was convicted of first degree felony murder, especially aggravated robbery, and being a felon in possession of a firearm for a May 11, 2017 shooting and robbery at Dellway Villa Apartments. 1
- At the scene, Jenkins and the victim argued over Chasity Hassell, and Jenkins later made a jail call implicating himself in the shooting and taking the victim's gun. 2
- Jenkins moved to appoint a second attorney, suppress his statements and jail call, and limit the codefendant's cross-examination about sentencing exposure. 3
- The trial court denied suppression, allowed the codefendant to be questioned only about facing a substantial prison sentence, and later instructed the jury on self-defense. 4
- At trial, the State relied on eyewitnesses, the codefendant, forensic evidence, and Jenkins's jail call; Jenkins testified that he shot in self-defense and that the codefendant fired the fatal shots. 5
- The court imposed life plus thirty-five years, including consecutive sentences, and denied new trial relief. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Second attorney appointment 7 | Jenkins claimed equal protection entitled him to two publicly funded lawyers. | State said the claim became moot when a second attorney actually represented Jenkins. | Claim moot; no relief. 8 |
| Suppression of statements and jail call 9 | Jenkins argued his Miranda waiver was invalid and December interview violated his right to counsel. | State argued he knowingly waived rights and no Sixth Amendment violation occurred. | Suppression properly denied. 10 |
| Corroboration of jail-call admissions 11 | Jenkins said his jail-call statements were uncorroborated and inadmissible. | State argued independent proof showed the statements were trustworthy. | Statements were sufficiently corroborated and admissible. 12 |
| Self-defense instruction after State's proof 13 | Jenkins said he was entitled to an immediate self-defense ruling without testifying. | State argued the issue was unpreserved and the court properly waited until the proof closed. | No error; instruction issue preserved only as tried and later given. 14 |
| Sufficiency and sentencing 15 | Jenkins challenged the robbery/murder proof and the high-risk-to-life and consecutive-sentence findings. | State argued the proof and sentence were supported by the record. | Evidence and sentence affirmed. 16 |
Key Cases Cited
- Newton v. Cox, 878 S.W.2d 105 (Tenn. 1994) (Tennessee follows federal equal-protection analysis 17)
- San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (U.S. 1973) (strict scrutiny applies to fundamental rights or suspect classes 18)
- Gideon v. Wainwright, 372 U.S. 335 (U.S. 1963) (indigent defendants have a right to counsel in felony prosecutions 19)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires warnings before waiver 20)
- State v. McKinney, 669 S.W.3d 753 (Tenn. 2023) (valid Miranda waiver must be voluntary, knowing, and intelligent 21)
- State v. Bishop, 431 S.W.3d 22 (Tenn. 2014) (extrajudicial confessions require corroboration showing trustworthiness 22)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review asks whether any rational juror could convict 23)
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (within-range sentencing reviewed for abuse of discretion with presumption of reasonableness 24)
- State v. Pollard, 432 S.W.3d 851 (Tenn. 2013) (consecutive sentencing reviewed for abuse of discretion 25)
