State of Tennessee v. Thomas Lee Hutchison
482 S.W.3d 893
Tenn.2016Background
- Victim found beaten and stabbed in Hutchison’s home on Feb. 20, 2002; responding officer (Shaffer) entered without warrant, detained persons, and found Hutchison injured and the victim deceased upstairs. Crime-scene technicians and investigators later processed the scene and collected items (crowbar, knife handle, clothing, a gold nugget ring, etc.).
- Autopsy performed Feb. 21, 2002 by Dr. Sandra K. Elkins (who later did not testify); report signed electronically by Elkins and attended by KPD personnel. Dr. Darinka Mileusnic-Polchan (then Chief Medical Examiner) testified at trial, relying on Elkins’s autopsy report and photos. Trial court admitted the autopsy report under the public-records exception and allowed Dr. Mileusnic-Polchan to give independent expert opinion.
- Hutchison convicted by jury of facilitation of first-degree murder (merged) and facilitation of especially aggravated robbery; sentenced to concurrent terms (17 and 8 years). Court of Criminal Appeals affirmed; one judge partially dissented on Confrontation Clause issue.
- On appeal to the Tennessee Supreme Court Hutchison argued (inter alia) that admission of Elkins’s autopsy report through Mileusnic-Polchan violated the Confrontation Clause, and that later warrantless entries/searches of his home exceeded any exigent-circumstances scope and required suppression.
- The Tennessee Supreme Court granted review, focusing on (1) admissibility of the autopsy report under the Confrontation Clause (Williams framework), and (2) whether subsequent officer/technician entries were a permissible continuation of an exigent-entry/plain-view seizure.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Hutchison) | Held |
|---|---|---|---|
| Admissibility of autopsy report/Confrontation Clause | Report was nontestimonial; Dr. Mileusnic-Polchan could rely on it and offer independent opinion | Autopsy report was testimonial (defendant was in custody; law enforcement present at autopsy); admitting it without Elkins violated the Confrontation Clause | Autopsy report was not testimonial under Williams framework; admission did not violate Confrontation Clause; Dr. Mileusnic-Polchan’s independent expert opinion was permissible |
| Whether expert may testify about another examiner’s report | Expert testimony based on underlying data is allowed; expert offered independent judgment | Expert impermissibly relayed testimonial out-of-court statements of a nontestifying witness | Permitted: expert may base opinion on another examiner’s report if testifying witness gives independent conclusions and is cross-examinable |
| Lawfulness of subsequent warrantless entries/searches of home | Initial exigent entry by Shaffer lawful; subsequent entries by other officers/technicians were a mere continuation and allowed seizure of items in plain view | Subsequent entries exceeded exigency scope; many items were not in plain view and should have been suppressed | Entry by subsequent officers/technicians was a continuation of lawful exigent entry; items in plain view admissible; non-plain-view items’ admission—if error—was harmless beyond a reasonable doubt |
| Admission of non-plain-view items (knife handle, sweatshirt, ring) | Even if beyond plain-view, their admission would be harmless because other properly admitted evidence overwhelmingly supported verdict | Admission of these items violated Fourth Amendment and should be suppressed; they were material to robbery/murder theories | Court need not decide inevitable-discovery here: any error admitting non-plain-view items was harmless beyond a reasonable doubt |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause bars admission of testimonial out-of-court statements unless witness unavailable and defendant had prior opportunity to cross-examine)
- Davis v. Washington, 547 U.S. 813 (2006) (primary-purpose test: statements made to meet an ongoing emergency are nontestimonial)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (forensic certificates prepared for prosecution are testimonial and implicate Confrontation Clause)
- Bullcoming v. New Mexico, 131 S. Ct. 2705 (2011) (admission of lab report through a surrogate witness who did not perform test violates Confrontation Clause)
- Williams v. Illinois, 132 S. Ct. 2221 (2012) (fractured opinions on when forensic reports are testimonial; plurality emphasized targeted-accusation; concurrence emphasized formality; dissent favored broader evidentiary-purpose test)
- Nix v. Williams, 467 U.S. 431 (1984) (inevitable discovery doctrine permits admission of evidence that would have been lawfully discovered)
- Mincey v. Arizona, 437 U.S. 385 (1978) (no blanket murder-scene exception to warrant requirement; exigent/emergency-aid exceptions recognized)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (warrantless entry permitted to render emergency aid or to prevent imminent injury)
- State v. Dotson, 450 S.W.3d 1 (Tenn. 2014) (Tennessee analysis of testimonial question for autopsy reports; framework applied here)
- Michigan v. Tyler, 436 U.S. 499 (1978) (subsequent entries to continue an initial lawful emergency entry can be lawful)
- State v. Coulter, 67 S.W.3d 3 (Tenn. Crim. App. 2001) (subsequent officers’ processing can be a mere continuation of initial exigent entry)