State of Tennessee v. Willie Austin Davis, M2019-01852-CCA-R3-CD

Davis, a former Covenant Presbyterian Church deacon, repeatedly emailed and appeared on Church property after receiving a 2008 letter banning him for alarming members; he was arrested after reentering in November 2015.
Indicted for aggravated criminal trespass (elevated to Class A because a private elementary school operated on the grounds), tried and convicted by a Davidson County jury in Sept. 2017.
Sentenced to 11 months, 29 days, suspended to supervised probation with no-contact conditions for current/former Church members and related school personnel.
Probation violations followed after Davis sent further mass emails; a different judge handled revocation and modification proceedings.
On appeal Davis (pro se) argued the trial judge should have disclosed/recused for associations with Church members, a lawyer (Worrick Robinson), a witness (John Bryant), and the judge’s relatives; he did not move to recuse at trial.
The Court of Criminal Appeals reviewed the claim under plain-error limited review, found no basis for reasonable question of impartiality, and affirmed the conviction and post-trial rulings.

Issue	State's Argument	Davis's Argument	Held
Whether the trial judge should have been disqualified for relationships with Church members/attorneys/witnesses and relatives	Issue waived (no in‑court recusal motion); plain‑error not shown	Judge was biased due to associations with Robinson, Bryant, judge’s father/uncle and influence over probation judges	Waived; no clear rule breached; impartiality not reasonably questioned; no plain error — claim denied

State v. Vance, 596 S.W.3d 229 (Tenn. 2020) (sets five‑factor plain‑error test)
State v. Clark, 610 S.W.3d 739 (Tenn. 2020) (recusal standard: whether a reasonable person knowing the judge’s facts would question impartiality)
State v. Banks, 271 S.W.3d 90 (Tenn. 2008) (error must likely have changed trial outcome to warrant relief)