State Supreme Court Upholds Death Sentence, Maintains Sentencing Review Standards For Death Penalty Cases

Tuesday, October 8, 2013

The Tennessee Supreme Court, in a 3-2 decision, has upheld a death sentence for a Memphis-area man who was convicted of first-degree felony murder after he killed an elderly man while stealing his car.

While the entire Court agreed that Corinio Pruitt was guilty, the dissenting justices would have modified the sentence to life without parole.

In reviewing a death penalty case, the Court is required by Tennessee law to conduct what is called a “proportionality review” to ensure that the sentence of death is appropriate in comparison to similar cases. Before conducting a proportionality review with the specific facts in the Pruitt case, the Court first considered whether the methods for such review should be modified. In fact, after the case was argued before the Tennessee Supreme Court in 2012, the Court determined that the issue of proportionality review required additional briefing and argument. After receiving supplementary information from the parties, the Court held oral arguments a second time earlier this year.

The primary issue is the pool of cases used to conduct the comparison in a death penalty case. In conducting its proportionality review, the Court looks at the pool of cases and considers the facts of the crimes, the characteristics of the defendants, and the circumstances of the crimes, with a goal of determining whether a death sentence is excessive or disproportionate.

In 1997, the Court determined that it would compare all death penalty sentences to other cases in which the death penalty was sought. Prior to that, the Court considered all cases in which a defendant had been convicted of first-degree murder, but was not necessarily considered for a death sentence.

The Court on Tuesday rejected the proposal by the defense that it should broaden the pool of cases to include all first-degree murder cases, including those in which the death penalty was never sought. Instead, the Court upheld its previous decisions since 1997 that have conducted a proportionality review by looking only at cases in which the state sought the death penalty and in which a penalty phase was held, regardless of the sentence actually imposed by the jury.

The Court ruled it was inappropriate to review the prosecutors’ initial decisions regarding whether to seek the death penalty at the onset of the case, reaffirming its 1997 Opinion which “noted that including these first degree murder cases in the pool would equate to an implicit review of prosecutorial discretion, that is generally not subject to judicial review.”

In the Pruitt case, the majority concludes that the sentence of death has not been imposed arbitrarily, that the evidence supports the jury’s finding of guilt, and that the sentence is not excessive or disproportionate.

In their separate opinion, Justice William C. Koch, Jr. and Justice Sharon G. Lee, after noting that all murders are serious crimes, stated that comparing all first-degree murder cases would be more consistent with the Tennessee law that requires proportionality review and with the rule that capital punishment is not appropriate for all murders but is reserved for only the most heinous murders and the most dangerous murderers.

The two dissenting justices also pointed to a 2007 American Bar Association study of Tennessee’s death penalty, which stated that the limited pool of cases the Court adopted in 1997 undercut the purpose of proportionality review. After considering Mr. Pruitt’s background and the nature of his crime in light of similar first-degree murder cases in Tennessee, the two justices determined that Mr. Pruitt should be sentenced to life imprisonment without the possibility of parole.

To read the majority opinion in State of Tennessee v. Corinio Pruitt, authored by Justice Janice M. Holder, as well as the concurring Opinion and dissent written by Justice Koch and Justice Lee, visit the Opinions section of TNCourts.gov


TBI Charges Morgan County Woman With Shooting Her Husband

Special Agents from the Tennessee Bureau of Investigation have arrested a Morgan County woman accused of shooting her husband on Friday . At the request of 9 th District Attorney General Russell Johnson, TBI Special Agents began investigating the incident, which occurred shortly after 5 p.m. at the family’s home on Morgan County Highway in Sunbright. There, authorities ... (click for more)

Latest Hamilton County Jail Booking Report

Here is the latest jail booking report from Hamilton County: ADKINS, ERIC WADE  8331 MIDDLE VALLEY ROAD HIXSON, 37343  Age at Arrest: 34 years old Arresting Agency: Hamilton County Booked for Previous Charges or Other Reason(s) ALFORD, JEFFERY LABRON  1549 MTN VIEW COURT CHATTANOOGA, 37409  Age at Arrest: 35 years old Arresting Agency: Chattanooga ... (click for more)

Could The Marriage Decision Spark A New Independence Day?

I confess that this year I am having a hard time with the idea of celebrating the 4th of July Independence Day. It is not because I am not thankful to God for what was done on that day, what it represents, and the blessings I’ve experienced that flow from it. On the other hand, I want to think that maybe this year’s celebration will mark a period in our history in which a new movement ... (click for more)

Roy Exum: Fourth Of July, 2015

As one who is about good and fed up with being “socially correct” so less than 10 percent of us can dictate how the other 90 percent of us ought to think, I am going to pause today in order to share a wonderfully fun email that has been around for a while. It is aptly called, “You Could Have Heard A Pin Drop.” Before I do, I got a sweet note the other day from my dear friend ... (click for more)

Weather Clears. Lookouts Drop Double-Header To Barons Friday

The Chattanooga Lookouts (44-31) dropped both game one, 3-1, and game two, 6-1, of tonight's doubleheader against the Birmingham Barons (38-38) in front of a sold-out crowd of 6,371.  This was the largest crowd of the year for Chattanooga and their first sell out of 2015. The Barons improved to 6-11 overall and 4-2 on the road against the Lookouts. Birmingham pulled even ... (click for more)

TSWA Announces All-State Softball Teams

 The Tennessee Sports Writers Association has announced its all-state high school softball teams for 2015. Local selections include: AAA - Kayla Boseman (Fr), Ooltewah and Hallie Davis (Sr), Walker Valley; AA - Kaili Crawley (Fr) of Central; A - McKenna Morgan (Jr), Sale Creek; and, Division II-AA - Lauren Lewis (Sr), Kayla Hughes (Sr) and Cheyenne Lindsey (Fr) of Baylor.  ... (click for more)