TBA Law Blog

TBA Law Blog

Tennessee Supreme Court Issues Unanimous Rulings on Criminal Case and Judicial Residency

Posted by: Azya Thornton on Mar 7, 2025

The Tennessee Supreme Court issued two unanimous decisions this week, addressing criminal law and judicial residency requirements. In State v. William Rimmel III, the court affirmed Rimmel’s attempted aggravated assault conviction but reversed his reckless endangerment conviction. The case stemmed from a 2018 road rage incident in Marion County, where Rimmel pursued Bobbie Burke on a motorcycle and smashed her car window with a loaded handgun. The court ruled that Burke’s knowledge of the gun was not required to uphold the assault conviction, as long as Rimmel intended to make her fear imminent bodily injury. However, it overturned the reckless endangerment conviction, finding that Rimmel’s actions did not create a reasonable probability of serious bodily injury or death since he never pointed the gun at Burke. In Robin M. McNabb v. Gregory H. Harrison, the court ruled that municipal judges in Tennessee must reside within the city they serve, as required by the Tennessee Constitution. The decision came after Gregory Harrison was elected Lenoir City municipal judge in 2022, despite not living within city limits. Robin McNabb, a losing candidate, challenged the election results, arguing that the constitutional residency requirement applies to the city, not a broader judicial district. The Supreme Court agreed, ruling that because Harrison did not reside in Lenoir City, he was ineligible for the position.

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