687 S.W.3d 223
Tenn.2024Background
- Triple homicide at a Memphis duplex on Sept. 26, 2015; victims were Anthony Isom, Chastity Springfield, and Michael Glover.
- Co-defendant Demarco Hawkins was severed, later confessed, and testified for the State against Tony Thomas and Laronda Turner at their joint trial.
- A jury convicted Thomas and Turner of three counts each of first-degree premeditated murder; both received life sentences.
- Defendants appealed raising multiple issues; the Court of Criminal Appeals affirmed by majority but one judge dissented as to (1) Turner’s sufficiency challenge and (2) alleged Brady violations for failure to disclose Hawkins’ proffer statements.
- Tennessee Supreme Court granted limited review of two issues: whether the State violated Brady by withholding Hawkins’ proffer-session statements, and whether evidence was sufficient to support Turner’s convictions.
- Holding: the Court (1) affirmed Thomas’s convictions (no Brady violation as to him), (2) reversed and dismissed Turner’s convictions for insufficient corroboration of accomplice testimony, and (3) prospectively abolished Tennessee’s common-law accomplice-corroboration rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady: nondisclosure of Hawkins’ proffer statements (Thomas) | Thomas: State withheld inconsistent proffer statements that were favorable/impeaching and material to guilt/strategy. | State: disclosure was delayed not withheld; statements cumulative; no reasonable probability of different outcome. | No Brady violation for Thomas — delayed disclosure not material; convictions affirmed. |
| Sufficiency of the evidence for Turner’s first-degree murder convictions | Turner: Hawkins was an accomplice whose testimony was unreliable and uncorroborated; verdict unsupported. | State: Hawkins’ testimony was corroborated (gang affiliation, car ID, broken glass/marijuana, jail call) and jury could credit it. | Evidence insufficient — accomplice testimony not adequately corroborated; Turner’s convictions reversed and charges dismissed. |
| Validity of the accomplice-corroboration rule | State sought to eliminate the common-law rule as outdated and inconsistent with majority jurisdictions. | Defense relied on existing Tennessee common-law protection that convictions cannot rest solely on uncorroborated accomplice testimony. | Court abolished the common-law accomplice-corroboration rule, returning weight/credibility assessment to juries, but provided a temporary cautionary jury instruction. Change applied prospectively. |
| Retroactivity of abrogation | Some urged retroactive application (benefit defendants / align precedent); others cautioned fairness concerns if retroactive. | Dissent argued for retroactivity and criticized prospective-only approach. | Court applied abolition prospectively only (mandate date forward) to avoid retroactive lowering of proof for past trials. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable material evidence to avoid due process violation)
- United States v. Bagley, 473 U.S. 667 (1985) (Brady includes impeachment evidence)
- Strickler v. Greene, 527 U.S. 263 (1999) (materiality standard: reasonable probability suppressed evidence would produce a different verdict)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- State v. Collier, 411 S.W.3d 886 (Tenn. 2013) (Tennessee accomplice-corroboration doctrine discussed)
- State v. Bigbee, 885 S.W.2d 797 (Tenn. 1994) (articulates test for corroboration of accomplice testimony)
- Rogers v. Tennessee, 532 U.S. 451 (2001) (discussion of retroactivity and due process constraints on post hoc judicial changes)
- State v. Jones, 216 A.3d 907 (Md. 2019) (Maryland high court abrogated its accomplice-corroboration rule and influenced Tennessee Court’s reasoning)