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


Many Waldens Ridge Scenes Featured In Stokes Picture Book

A number of early views of Waldens Ridge are among the rarities found in the Stokes Photo Collection. There are many photos of the roads up the mountain showing streetcars, wagons and early autos. There are scenes at Rainbow Lake, Falling Water Falls, Signal Point and other scenic spots. Several photos are included of the Signal Mountain Hotel. The more than 700 photos ... (click for more)

Man Shot At Apartments On Tunnel Boulevard Wednesday Afternoon Dies; 2 Juveniles Shot At Rec Center On Oakwood Drive With Suspects In Custody

A 24-year-old man who was shot at the apartment buildings at 404 Tunnel Blvd. on Wednesday at 1:21 p.m. has died. He was identified as Kenny Breylon Hall. Residents said they heard multiple shots fired.  Witnesses said they saw multiple suspects fleeing the scene on foot behind the complex.  Later Wednesday, two people were shot at the Washington Hills Recreation ... (click for more)

Chairs Cost How Much?

Many times while growing up, I would go to the store with my parents. More often than not, I would see something I wanted, and ask my parents to buy it for me. More often than not, they said no. “Why?” I asked. “Son, money doesn’t grow on trees.” That’s a phrase I’m sure many of us have heard more than once over the course of our lives. However, I have since learned that they were ... (click for more)

Roy Exum: My Dear Friend Luther

One sunny morning in June years ago, the renowned radio icon Luther Masingill was on his way back to the WDEF studios on South Broad Street when he stopped for a red light and noticed a young couple in a car idling next to his familiar light blue Ford pickup. “What caught my eye was a buck-toothed boy eating a banana in the back seat,” he explained in an aside to that day’s lunchtime ... (click for more)

Signal Mountain Falls In State Volleyball Semis

SMYRNA, Tenn. – It’s a good thing that Signal Mountain volleyball coach Jennifer Redman is a young lady because her heart might not be able to stand the pressure if she wasn’t. Redman’s Lady Eagles were thisclose to being sent to the loser’s bracket in the opening round of the State Volleyball Tournament here at Stewarts Creek High School Wednesday afternoon. Had it been a ... (click for more)

Boyd-Buchanan Sweeps Loretto To Open Class A State Volleyball

MURFREESBORO, Tenn. – Playing what coach Alfie Dodd called a sub-par match, Boyd-Buchanan’s Lady Bucs were still good enough to sweep Loretto, 3-0, Wednesday morning in the opening match of the Tennessee Secondary School Athletic Association’s Class A state volleyball tournament at Blackman High School. Set scores were 25-19, 25-14, 25-20. “We advance and we know we can ... (click for more)