State v. Watkins
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Defendant was convicted of reckless homicide and aggravated child abuse after killing a thirteen-month-old by deliberately striking the child's head against a wall. The court of criminal appeals determined on its own motion that Defendant's dual convictions violated the double jeopardy protections of the federal and state constitutions. Accordingly, the court merged the reckless homicide conviction into the aggravated child abuse conviction and remanded for resentencing. The Supreme Court reversed the portion of the court of criminal appeals' judgment merging the convictions and reinstated the reckless homicide conviction, (1) abandoning the four-factor set forth in State v. Denton; (2) adopting the elements test enunciated in Blockburger v. U.S. as the test for determining whether multiple convictions under different statutes constitute the same offense for purposes of the double jeopardy clause of the Tennessee Constitution; and (3) concluding that reckless homicide and aggravated child abuse are not the same offense because their elements differ, and thus, Defendant's dual convictions did not violate either the federal or the state constitutional double jeopardy prohibition.
Court Description: Authoring Judge: Chief Justice Cornelia A. Clark
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