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

Tuesday, October 08, 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


Stokes Photo Book At Zarzours Daily This Week, Other Locations

The Stokes photo book of rare old Chattanooga pictures, which sold out the initial edition of 1,000 copies, will be available at Zarzours Restaurant on Rossville Ave. off Main Street behind Fire Hall #1 this coming week Monday-Friday from 11 a.m.-3 p.m. each day. Chattanooga In Photos Around the Turn of the Century: The Remarkable Stokes Collection is also available at ... (click for more)

Alexander Announces Committee Assignments For Next Congress

Senator Lamar Alexander on Thursday announced that next Congress he will serve on the following committees:   ·   Health, Education, Labor and Pensions, where he is the ranking Republican member ·   Appropriations, where he is the ranking Republican member on the subcommittee that oversees energy and water appropriations ·  Energy and Natural ... (click for more)

A Letter To The NAACP

I believe when a "unarmed" man is evil, he will try to beat a police officer on his head in hopes to knock him out, in hopes to kill him. We saw the bruises on the officer's face.  This evil force tried to take his gun away from him , Proof was in the autopsy.  Why did Michael Brown  try to take his gun away from him? Exactly, to kill the officer.  ... (click for more)

Roy Exum: The Last Day Of School

AUTHOR’S NOTE: This story first appeared in the Chattanooga News-Free Press in the early 1980s and every year since then I have been asked repeatedly about it. It is easily the most famous story I have ever written – copies have been sent to me from numerous foreign countries -- and it may be the easiest story I ever wrote. All I did was write what the noted religious psychologist ... (click for more)

UTC Cagers Upset No.7 Stanford

"Defense kept us in the game and our fans are great!." UTC sophomore Moses Johnson after the 54-46 win.   The giant killer has done it again. Relying on hustle, determination, key 3-pointers and 10 made free throws down the stretch the Chattanooga Mocs defeated visiting No.7 Stanford women 54-46 Wednesday at McKenzie Arena. Playing before 2,128 cheering ... (click for more)

Vols Land 4-Star JUCO Running Back Alvin Kamara

KNOXVILLE, Tenn. – Tennessee football coach Butch Jones has signed junior college four-star running back Alvin Kamara, who is from Norcross, Ga., and originally signed with Alabama and then transferred to Hutchinson (Kan.) Community College. Information on Kamara: ALVIN KAMARA R-Sophomore • Running Back • 5-11 • 200 Norcross, Ga. • Norcross H.S./Alabama/Hutchinson ... (click for more)