State v. Turner
352 S.W.3d 425
| Tenn. | 2011Background
- Turner was indicted for the 1995 murder of Emily Fisher in Shelby County.
- Two co-suspects, Rodney Blades and George Tate, were previously tried and acquitted in 1996.
- Turner sought to exclude references to Blades’ and Tate’s acquittals on relevance and prejudice grounds.
- The State sought to admit acquittals to provide credibility context and rebut Turner’s theory that Blades and Tate committed the murder.
- The trial court allowed the State to mention the acquittals in opening statement; many prior-trial witnesses were unavailable.
- Turner was convicted of facilitation of felony murder and facilitation of second-degree murder; sentences merged to 25 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are acquittals admissible as context evidence? | State contends acquittals fill a chronological void and aid credibility. | Turner argues acquittals are irrelevant and prejudicial. | Acquittals are inadmissible as context evidence. |
| Are acquittals admissible to attack credibility? | State asserts credibility of Blades and Tate is at issue. | Turner contends it would be premature and unhelpful for credibility evidence. | Admitting acquittals to attack credibility is improper. |
| Can acquittals rebut Turner's defense theory that others committed the crime? | State argues acquittals could rebut Turner’s theory. | Turner argues the evidence does not make Blades/Tate more or less probable killers. | Acquittals do not make the others more probable killers; their admission is reversible error. |
Key Cases Cited
- Gilliland v. State, 22 S.W.3d 266 (Tenn. 2000) (context evidence requires specific balancing; improper if void or prejudicial)
- State v. Rodriguez, 254 S.W.3d 361 (Tenn. 2008) (harms of unfair prejudice; non-harmless error standard for evidentiary rulings)
- State v. Denton, 938 S.W.2d 373 (Tenn. 1996) (double jeopardy considerations; protection against self-incrimination)
- State v. Rice, 184 S.W.3d 646 (Tenn. 2006) (defense rights to present evidence against co-perpetrator theory)
- State v. Powers, 101 S.W.3d 383 (Tenn. 2003) (defendant’s right to present evidence of another offender)
- Holmes v. South Carolina, 547 U.S. 319 (U.S. 2006) (defendant's right to offer a defense; evidentiary balance constraints)