STATE OF TENNESSEE v. EZEKIEL ABRAHAM SCHMALTZ - Articles

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Posted by: Azya Thornton on Oct 29, 2025

Court: TN Court of Criminal Appeals

Attorneys 1: Mary J. Newton (on appeal and at trial); and Chelsea C. Moore (at trial), for the appellant, Ezekiel Abraham Schmaltz.

Attorneys 2: Jonathan Skrmetti, Attorney General and Reporter; Caroline Weldon, Assistant Attorney General; Charme P. Allen, District Attorney General; and Ashley McDermott and Franklin Ammons, Assistant District Attorneys General, for the appellee, State of Tennessee.

Judge(s): SWORD

The Defendant, Ezekiel Abraham Schmaltz, appeals his Knox County jury convictions of two counts of observation without consent and one count of assault, for which he received an effective sentence of two years and six months’ incarceration. On appeal, the Defendant argues (1) the evidence was insufficient to sustain his convictions, (2) the State committed prosecutorial misconduct by discussing punishment with the prospective jurors during voir dire, (3) the trial court erred by admitting extrinsic proof of the victim’s prior consistent statements to rehabilitate her credibility, (4) the trial court erred by restricting the Defendant’s ability to cross-examine two State’s witnesses, and (5) the cumulative effect of trial errors entitles him to a new trial. Following our review, we remand the case for merger of the Defendant’s convictions of observation without consent into a single conviction and the entry of corrected judgments. We otherwise affirm the judgments of the trial cour

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