Tennessee Supreme Court Upholds Hamilton County Court's Decision To Exclude Videotape Of Post-Polygraph Statements

Thursday, August 22, 2019
In an opinion released Wednesday, the Tennessee Supreme Court held that a trial court acted within its discretion in excluding from trial a defendant’s videotaped statements given in a post-polygraph interview. In so doing, the Court reversed the decision of the Court of Criminal Appeals.

The defendant, Quintis McCaleb, was indicted on one count of aggravated sexual battery and two counts of rape of a child in Hamilton County.   During the investigation of the charges, Mr. McCaleb agreed to take a polygraph examination.  At the end of the examination, a law enforcement officer additionally interrogated Mr.
McCaleb. Many of the questions contained references to the polygraph.  Mr. McCaleb sought to suppress the videotape of these statements.  Any testimony related to polygraphs is strictly prohibited under Tennessee law.  The trial court held that the statements should not be admitted because of the many references to the polygraph.

The State then pursued an interlocutory appeal, and the Court of Criminal Appeals held that the trial court abused its discretion in excluding the videotape of Mr. McCaleb’s statements from trial.  The intermediate court held that the trial court possibly could have admitted into evidence a redacted portion of the videotaped interrogation, even though no redacted version had been offered by the State.  As a result, the Court of Criminal Appeals reversed the trial court’s decision.  The Supreme Court then granted Mr. McCaleb’s application for permission to appeal.

The Supreme Court held that the trial court acted within its discretion in determining that the videotape of Mr. McCaleb’s post-polygraph statements should be excluded from trial.  In reaching this decision, the Court noted that a trial court has broad discretion in determining whether particular evidence should be admitted at trial.  As a result, as long as the trial court’s action was an objectively reasonable decision, an appellate court should not substitute its judgment for that of the trial court. Instead, it should uphold that decision, even if the appellate court would have reached a different result.  Under the facts of this case, the decision by the trial court was a reasonable option.  Therefore, the trial court did not err in deciding to exclude the evidence.   Accordingly, the Supreme Court reversed the judgment of the Court of Criminal Appeals and remanded the matter to the trial court for further proceedings.

To read the Supreme Court’s opinion in State of Tennessee v. Quintis McCaleb, authored by Chief Justice Jeff Bivins, go to the opinions section of TNCourts.gov.

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