State of Tennessee v. Tyler Ward Enix, 653 S.W.3d 692

Tyler Enix was convicted of premeditated first-degree murder and especially aggravated robbery for the October 2015 killing of his ex‑wife; the jury heard evidence including 47 stab wounds, DNA under the victim’s fingernails matching Enix, the victim’s blood on tissues and on Enix’s jeans, threatening texts, ATM photos showing Enix driving the victim’s car, and his flight to Ohio with the child.
At trial the defense conceded the stabbing but argued it was a heat‑of‑passion killing and that any taking of property was not part of a robbery.
During the State’s closing the prosecutor made several contested remarks (counting 47 stab wounds while allegedly pounding the table and panting; speculating that Enix smashed the victim’s iPhone; calling Enix a “coward” for not fleeing police; suggesting he was headed north to Canada); defense made no contemporaneous objections but raised four of those claims in a motion for new trial.
The trial court denied the motion for new trial; the Court of Criminal Appeals applied plain‑error review and affirmed; Enix argued this Court should apply plenary review because he included the claims in his motion for new trial.
The Supreme Court granted review to decide the correct standard of review for unpreserved prosecutorial‑misconduct claims raised in a motion for new trial and whether Enix was entitled to relief.

Issue	Enix's Argument	State's Argument	Held
Standard of review for alleged prosecutorial misconduct during closing argument when no contemporaneous objection but issue raised in motion for new trial	Hawkins requires plenary review when issue is included in motion for new trial	Longstanding Tennessee law requires a contemporaneous objection; plain error applies to unpreserved claims	Plain error review is the correct standard; Hawkins is overruled to the extent inconsistent
Whether the prosecutor’s disputed remarks (counting/pounding; iPhone speculation; “coward”; north/Canada) warrant reversal under plain‑error review	Remarks were speculative, inflammatory, and prejudicial and affected Enix’s substantial rights	Remarks were within allowable argument or reasonable inference; overwhelming evidence of premeditation; no prejudice	No substantial right was affected; plain‑error prerequisites not met; convictions affirmed

State v. Hawkins, 519 S.W.3d 1 (Tenn. 2017) (addressed prosecutorial‑argument claims raised in motion for new trial; court applied plenary review to some claims)
State v. Sutton, 562 S.W.2d 820 (Tenn. 1978) (failure to contemporaneously object waives issue on appeal)
State v. Dotson, 450 S.W.3d 1 (Tenn. 2014) (sets five prerequisites for relief under plain‑error doctrine)
State v. Minor, 546 S.W.3d 59 (Tenn. 2018) (explains preservation principles and purpose of contemporaneous objections)
State v. Banks, 271 S.W.3d 90 (Tenn. 2008) (explains permissible scope of closing argument and when improper remarks warrant reversal)
State v. Rimmer, 623 S.W.3d 235 (Tenn. 2021) (clarifies that a substantial right is affected only if the error prejudiced the outcome)
State v. Walls, 537 S.W.3d 892 (Tenn. 2017) (discusses when counsel need not renew objections after definitive pretrial rulings)