State of Tennessee v. Travis Kinte Echols
2012 Tenn. LEXIS 738
| Tenn. | 2012Background
- Police responded to a Townview Towers shooting; victim found in car with gunshots and wallet missing; crime scene yielded firearms and shell casings; investigation linked defendant via informant and a resident Ms. Harshaw; defendant was arrested at Harshaw’s apartment after description matched; Miranda rights given and a taped confession obtained; suppression motions argued that arrest was unlawful but later rulings held probable cause supported arrest and waiver valid; trial followed with multiple witnesses and a self-defense claim ultimately rejected.
- Defense argued statements were tainted by unlawful detention; suppression court found close probable cause but ultimately admitted the statement; on appeal, the Court of Criminal Appeals suppressed the statement but affirmed conviction as harmless error; Tennessee Supreme Court granted review to address arrest validity and standard of harmless error review.
- Evidence included eyewitness Hammontree, Carpenter, and Blackwell testimony, with the defendant admitting shooting but claiming self-defense; State presented direct and circumstantial evidence of robbery and intent; jury found felony murder during a robbery; defendant testified he acted in self-defense and disposed of the gun.
- Cross-examination limitations of Hammontree, Thomas, and Investigator Still were challenged; court held some limitations were constitutional errors but harmless beyond a reasonable doubt given other corroborating evidence; redactions of Still’s interview were improperly curtailed but harmless overall.
- The Court held probable cause supported warrantless arrest; Miranda waiver voluntary; Batson challenge properly denied as racially neutral; sufficient evidence supports conviction; cross-examination errors were harmless; judgment affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for arrest and admissibility | Echols contends arrest lacked probable cause. | Echols argues arrest based on scant information and prior unverified tip. | Probable cause existed; statement properly admitted. |
| Miranda waiver voluntariness | State argues waiver voluntary. | Waiver was involuntary due to circumstances. | Waiver knowingly, intelligently, and voluntarily made. |
| Batson challenge to juror exclusion | State’s peremptory strike was race-neutral. | Strike targeted African American juror. | No purposeful discrimination; challenge properly denied. |
| Sufficiency of evidence for felony murder | State presented direct and circumstantial evidence of robbery. | Self-defense created reasonable doubt. | Evidence sufficient beyond a reasonable doubt. |
| Cross-examination and redacted interview | Limiting cross-examination of witnesses and redacted portions was improper. | Restrictions violated confrontational rights and 40-35-201(b). | Harmless beyond a reasonable doubt; rulings affirmed as harmless. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (prosecutor's race-based peremptory challenges violate equal protection)
- Powers v. Ohio, 499 U.S. 400 (U.S. 1991) (rights of non-defendant jurors to challenge discrimination)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for appellate review of evidence sufficiency)
- Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (evidence of confession circumstances relevant to defense viability)
- Dorantes v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (unified standard for direct and circumstantial evidence sufficiency)
- Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (standard for reviewing sufficiency with strongest view of evidence)
- State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (standard for findings of fact in suppression appeals binding unless preponderated)