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


Latest Hamilton County Jail Booking Report

Here is the latest jail booking report from Hamilton County: BAILEY, JOYCE MARIE  2702 E 39TH STREET CHATTANOOGA, 37407  Age at Arrest: 39 years old Arresting Agency: Chattanooga CRIMINAL TRESPASSING THEFT OF PROPERTY (UNDER $500) --- BATES, JEREMY M  707 PARK AVE CHATTANOOGA, 37403  Age at Arrest: 36 years old Arresting Agency: Chattanooga ... (click for more)

Latest Hamilton County Jail Booking Report

Here is the latest jail booking report from Hamilton County: AARON, STEVE LYNN  2518 CRESCENT CLUB DR HIXSON, 37343  Age at Arrest: 50 years old Arresting Agency: East Ridge DOMESTIC ASSAULT DOMESTIC ASSAULT --- AKINS, JAVORIS  7604 STANDIFER GAP RD CHATTANOOGA, 37421  Age at Arrest: 20 years old Arresting Agency: Chattanooga DRIVING ... (click for more)

Parking Discrimination Downtown

Many taxpayers who reside in Chattanooga (but outside Chattanooga's core) feel left behind when it comes to neighborhood paving, sidewalks, policing, streetscaping, street sweeping, public transportation, and other services. Some think most tax dollars are spent on downtown and not in their neighborhoods. It's not as if they can't vicariously experience the largesse of downtown. ... (click for more)

Roy Exum: One Nameless Ghost

One hundred years ago the United States was at war. The most intense fighting during World War I was on what was called The Western Front. The Germans wanted to invade France from the north and in order to do it, they had to push through Flanders province in Belgium. It has been described as a hell unequalled in raw hand-to-hand combat, In just four months on Flanders fields, ... (click for more)

Smokies' Hurlers Limit Lookouts To Four Hits Sunday In 5-1 Win

The Lookouts drew six walks, but only managed four hits in their 5-1 loss to the Tennessee Smokies Sunday in front of a crowd of 5,356 fans at AT&T Field.    Chattanooga's loss drops them to 22-28 through 50 games in the Southern League North Division. Tennessee starting pitcher Brad Markey was lights out early for the Smokies, carrying a no-hitter into ... (click for more)

Tennessee-Georgia All-Star Football Classic Set For Saturday at CCS

The 13th Annual Tennessee-Georgia All-Star Football Classic, presented by Great Clips, is scheduled for 7 p.m. Saturday June 4 at Chattanooga Christian School in Chattanooga. Tennessee defeated Georgia 38-14 last June at McCallie School in Chattanooga. It was Tennessee's fourth consecutive victory in the series that dates back to the first game held at Ridgeland High in ... (click for more)