State of Tennessee v. William Eugene Hall, 2015 Tenn. LEXIS 241

Background

Defendant William Eugene Hall escaped from Kentucky prison in June 1988 and, with co-defendants, committed a series of burglaries in Stewart County, Tennessee; Myrtle and Buford Vester were murdered during one burglary.
Hall was tried jointly (1991–92), convicted of two counts of felony murder (during first-degree burglary), multiple larcenies and burglaries; jury sentenced Hall to death for Myrtle Vester’s murder and life for Buford Vester’s murder; additional terms totaled eighty years.
On direct appeal and in this Court’s earlier review, convictions and death sentence were affirmed; Hall later obtained a delayed appeal because his original appellate counsel largely copied a co-defendant’s brief, depriving him of meaningful appellate representation.
On remand Hall filed new and amended motions for new trial and reasserted coram nobis claims based on purportedly “new” evidence (inmates’ testimony that co-defendant Blanton confessed and alibi evidence linked to Quintero’s father); judges at multiple levels rejected credibility of this evidence.
Successor trial judge (Blackwood) entertained parts of the delayed appeal (limited scope), denied new trial and coram nobis relief; Court of Criminal Appeals affirmed; Tennessee Supreme Court affirms, addressing successor judge role, coram nobis, shackling, sufficiency, and capital-sentencing claims.

Issues

Issue	Plaintiff's Argument (Hall)	Defendant's Argument (State)	Held
Successor judge authority to rule after original judge’s death	Judge Blackwood had to grant new trial because original judge died before resolving all motions and statutory law once required automatic new trial	Successor judge may rule after reviewing record; prior judge had already ruled as thirteenth juror and original post-trial motion was disposed	Court: No automatic new trial; Wallace had acted as thirteenth juror post-trial and later motions fell outside old statute’s scope; Blackwood properly ruled as successor judge
Coram nobis / newly discovered evidence (Blanton confession, alibi)	Newly discovered inmate testimony and family alibi evidence would likely change verdict; counsel was not given chance to present it at trial	Evidence lacked credibility, discovery was delayed/suspicious, and defendants were not diligent in presenting alibi at trial	Court: Denied coram nobis — evidence not credible or likely to change result; no abuse of discretion
Use of shackles in view of jury	Juror(s) saw Hall in shackles; shackling prejudiced guilt/penalty decisions and warranted new trial	Shackles were leg irons removed/hidden from jury view; court exercised discretion given security concerns; precautions and record supported use	Court: No violation — shackling was limited, justified by security/escape risk, and no showing of prejudice
Sufficiency of the evidence for convictions	Evidence was largely circumstantial and insufficient to prove Hall’s participation in murders beyond reasonable doubt	Circumstantial and direct evidence (fingerprints, items recovered, identifications, vehicle linking, timeline) supported convictions	Court: Evidence, viewed in light most favorable to State, was sufficient under Jackson standard; convictions stand

Key Cases Cited

State v. Blanton, 975 S.W.2d 269 (Tenn. 1998) (related capital case and precedent cited regarding trial/jury matters)
State v. Hall, 976 S.W.2d 121 (Tenn. 1998) (Court’s prior direct-appeal decision affirming convictions and death sentence)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (adopting Jackson standard equivalency for circumstantial and direct evidence)
Jackson v. Virginia, 443 U.S. 307 (1979) (establishing the legal-sufficiency standard: verdict must be sustainable by any rational trier of fact)
State v. Mixon, 983 S.W.2d 661 (Tenn. 1999) (describing coram nobis as extraordinary relief and setting stringent standards)
State v. Moats, 906 S.W.2d 431 (Tenn. 1995) (describing thirteenth juror role of trial judge in weighing evidence)
State v. Ellis, 453 S.W.3d 889 (Tenn. 2015) (discussing successor judge’s evaluation and presumption favoring successor acting as thirteenth juror)
Mobley v. State, 397 S.W.3d 70 (Tenn. 2013) (outlining due-process concerns and standards for shackling defendants)