STATE OF TENNESSEE v. JOHN HENRY PRUITT - Articles

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Posted by: Stacey Shrader Joslin on Dec 30, 2016

Court: TN Supreme Court

Attorneys 1:

Vanessa Pettigrew Bryan, District Public Defender; J. Gregory Burlison (at trial and on appeal), and Robert Jones (at trial), Assistant District Public Defenders, for the appellant, John Henry Pruitt.

Attorneys 2:

Herbert H. Slatery III, Attorney General and Reporter; Andrée S. Blumstein, Solicitor General; Sarah K. Campbell, Special Assistant to the Solicitor General and the Attorney General; Kim Helper, District Attorney General; Michael J. Fahey and Kate Yeager, Assistant District Attorneys General, for the appellee, State of Tennessee.

Judge(s): PAGE

We granted this appeal to consider whether the Court of Criminal Appeals incorrectly held in State v. Hayes, No. M2012-01768-CCA-R3-CD, 2013 WL 3378320, at *7 (Tenn. Crim. App. July 1, 2013), no perm. app. filed, that retroactive application of the Exclusionary Rule Reform Act, Tennessee Code Annotated section 40-6-108, would violate constitutional protections against ex post facto laws and to re-evaluate the ex post facto analysis in Miller v. State, 584 S.W.2d 758 (Tenn. 1979), in light of Collins v. Youngblood, 497 U.S. 37 (1990). Having concluded that Miller was wrongly decided, we overrule Miller and hold that the ex post facto clause of the Tennessee Constitution has the same definition and scope as the federal ex post facto clause. To be an ex post facto violation, a law must be retroactive in its application and must fall within one of the four categories set forth in Calder v. Bull, 3 U.S. (3 Dall.) 386, 390 (1798) (opinion of Chase, J.). We conclude that the Exclusionary Rule Reform Act is not an ex post facto statute as applied in this case and that as a result, the Defendant's motion to suppress the evidence against him was not well-taken. In addition, we conclude that the Defendant's issues regarding the sufficiency of the evidence to convict him and to sentence him to life without the possibility of parole do not entitle him to relief. Accordingly, the judgments of the Court of Criminal Appeals are affirmed on the separate grounds stated herein.

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