State of Tennessee v. Zachary Everett Davis, M2016-01579-CCA-R3-CD

Background

In August 2012, then-15-year-old Zachary Davis struck his mother multiple times with a sledgehammer, set a fire in the home, and fled; he was arrested the next morning and gave a statement admitting the killing and arson. He was charged with first-degree premeditated murder, attempted first-degree murder, and aggravated arson and transferred to adult criminal court.
Multiple forensic evaluators (two finding incompetence; two at MTMHI finding competence) assessed Davis over repeated inpatient and outpatient evaluations focusing on psychosis, depression, and possible autism-spectrum features. MTMHI clinicians (Drs. Farooque and Craddock) concluded Davis was competent after extended observation; others (Drs. Phillips and Freeman) opined he was psychotic and could not reliably assist counsel.
The trial court held hearings on competency and suppression; it credited MTMHI clinicians and found Davis competent to stand trial. The court also denied suppression of Davis’s custodial statement (juvenile without parent present) after police sought juvenile-court authorization and confirmed Davis understood Miranda warnings.
At trial Davis initially had admitted the offenses in prior statements, but while testifying he recanted—claiming his brother actually killed their mother and he took the blame—prompting defense counsel to move for a mistrial and renew the competency claim; the trial court denied both motions.
A jury convicted Davis on all counts. The court imposed life for first-degree murder and consecutive aggregate sentences (twenty years each for attempted murder and arson, ordered consecutive to life), producing an effective life-plus-terms sentence. Davis appealed, arguing error on competency, suppression, mistrial, and that the aggregate result produced a de facto life-without-parole sentence unconstitutional under Eighth Amendment juvenile-sentencing precedents.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Davis)	Held
Competency to stand trial (initial)	MTMHI clinicians’ evaluations supported competence; trial court properly credited them.	Davis lacked ability to rationally consult or assist counsel due to psychosis/communication deficits.	Trial court’s finding of competence affirmed; evidence did not preponderate against crediting MTMHI clinicians.
Competency mid-trial (renewed)	Prior extensive evaluations and court observations show no reasonable doubt; no new evidence requiring another hearing.	Mid-trial recantation (blaming brother) proved inability to cooperate and thus incompetence.	Denial of renewed competency motion affirmed; a reasonable judge would not have experienced doubt requiring a new evaluation.
Suppression of custodial statement (juvenile without parent/mental illness)	Police obtained juvenile-court authorization, read/confirmed Miranda comprehension, and no coercion; waiver voluntary under totality of circumstances.	Juvenile status and mental illness rendered waiver involuntary and required a parent/advisor presence.	Denial of suppression affirmed: court applied Callahan totality factors and found voluntary, knowing, and intelligent waiver.
Mistrial after defendant’s trial testimony contradicting prior statements	State: trial should continue; defendant chose to testify inconsistently.	Defense: unexpected change undermined counsel’s strategy and ability to defend; mistrial required.	Denial of mistrial affirmed; no manifest necessity—State did not elicit the testimony, evidence against defendant was strong.
Eighth Amendment challenge to consecutive sentences (de facto life without parole)	Miller/Montgomery inapplicable because Tennessee does not mandate life without parole; Davis received discretionary life with parole possibility.	Consecutive alignment (life + decades) creates a de facto life-without-parole for a juvenile, violating Eighth Amendment.	Denial affirmed: Miller limited to mandatory LWOP schemes; Tennessee sentencing here permissible.

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings and waiver principles)
Dusky v. United States, 362 U.S. 402 (1960) (standard for competency to stand trial)
Miller v. Alabama, 567 U.S. 460 (2012) (Eighth Amendment forbids mandatory LWOP for juveniles)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller rule is substantive and retroactive)
State v. Blackstock, 19 S.W.3d 200 (Tenn. 2000) (Tennessee competency standard)
State v. Callahan, 979 S.W.2d 577 (Tenn. 1998) (totality-of-circumstances test for juvenile Miranda waivers)
State v. Climer, 400 S.W.3d 537 (Tenn. 2013) (confession voluntariness and coercion analysis)