The Tennessee Supreme Court on Thursday upheld the premeditated first-degree murder and aggravated robbery convictions of Kemontea Dovon McKinney (“Defendant”) for the killing of Jonathan Outlaw in Robertson County. The Court found the Defendant’s statements to detectives were voluntary, as was the waiver of his Miranda rights.
In October 2017, Defendant, a juvenile at the time of the offenses, shot and killed Mr.
Outlaw when Defendant and two accomplices met Mr. Outlaw after his Camaro was listed for sale on Craigslist. At the police station, detectives read Defendant his
Miranda rights and interrogated him with his mother present.
Prior to trial, Defendant filed a motion to suppress his statements made to detectives, arguing that he did not knowingly and voluntarily waive his Miranda rights. The trial court denied the motion to suppress and admitted Defendant’s pretrial statements into evidence.
Following his convictions, Defendant appealed to the Court of Criminal Appeals. The intermediate court held that the trial court erred by denying Defendant’s motion to suppress and that admitting Defendant’s statements into evidence was not harmless beyond a reasonable doubt. The Court of Criminal Appeals provided that “whether the defendant voluntarily provided a statement to the police is inextricably linked with the question whether the defendant voluntarily waived his constitutional right to remain silent by providing a statement after the warnings were given,” such that the two inquiries can be considered together. The Court of Criminal Appeals also held that the evidence was not sufficient to support Defendant’s premediated first-degree murder conviction.
Under the United States and Tennessee Constitutions, a defendant’s confession to police must be voluntary. Additionally, Miranda v. Arizona, 384 U.S. 426 (1966), requires police to provide criminal defendants with certain rights prior to a custodial interrogation, and police must obtain a knowing and voluntary waiver of those rights for the statements to be admissible as evidence of guilt. Relevant to the facts of this case, juveniles may also waive their Miranda rights.
The Supreme Court granted the State’s application for permission to appeal to consider whether the intermediate court erred when it stated that an involuntary-confession claim is “inextricably linked” to a Miranda-waiver claim. The Court also granted the State’s application to consider whether the Court of Criminal Appeals erred in determining that the evidence was insufficient to support Defendant’s conviction for premeditated first-degree murder.
Reviewing the applicable case law, the Court re-emphasized that the voluntariness test is distinct from the test for Miranda waiver, despite similarities between the analyses. After separately applying both tests, the Court concluded that Defendant’s overall statement was voluntary and his Miranda waiver was both knowing and voluntary. The Court also concluded that the evidence presented by the State was sufficient to support Defendant’s conviction for premeditated first-degree murder. As a result, the Court reversed the Court of Criminal Appeals and reinstated the trial court’s judgments.
Oral arguments in this case were heard at East Tennessee State University as part of the Supreme Court’s SCALES program.
To read the unanimous opinion in State v. Kemontea Dovon McKinney, authored by Chief Justice Roger A. Page, visit the opinions section of TNCourts.gov.