State v. PruittAnnotate this Case
Defendant was indicted for, inter alia, two counts of first degree premeditated murder. The trial court denied Defendant’s motion to suppress evidence seized from his residence, ruling that the Exclusionary Rule Reform Act applied to the case despite ex post facto concerns. The jury then convicted Defendant as charged. The jury sentenced Defendant to life sentences without the possibility of parole for the murders. The court of criminal appeals upheld Defendant’s convictions and sentences. At issue before the Supreme Court was whether the Court should modify the Tennessee ex post facto analysis found in Miller v. State in light of Collins v. Youngblood. The Supreme Court affirmed on separate grounds, holding (1) Miller v. State is overruled; (2) the ex post facto clause of the Tennessee Constitution has the same definition and scope as the federal ex post facto clause; (3) the application of the Exclusionary Rule Reform Act to this case was not an ex post facto violation; (4) the trial court did not err in denying Defendant’s motion to suppress evidence obtained as a result of a search warrant; and (5) Defendant was not entitled to relief on his remaining issues.
Authoring Judge: Justice Roger A. Page
Trial Court Judge: Judge Timothy L. Easter
We granted this appeal to consider whether the Court of Criminal Appeals incorrectly held in State v. Hayes, No. M2012-01768-CCA-R3-CD, 2013 WL 3378320, at *7 (Tenn. Crim. App. July 1, 2013), no perm. app. filed, that retroactive application of the Exclusionary Rule Reform Act, Tennessee Code Annotated section 40-6-108, would violate constitutional protections against ex post facto laws and to re-evaluate the ex post facto analysis in Miller v. State, 584 S.W.2d 758 (Tenn. 1979), in light of Collins v. Youngblood, 497 U.S. 37 (1990). Having concluded that Miller was wrongly decided, we overrule Miller and hold that the ex post facto clause of the Tennessee Constitution has the same definition and scope as the federal ex post facto clause. To be an ex post facto violation, a law must be retroactive in its application and must fall within one of the four categories set forth in Calder v. Bull, 3 U.S. (3 Dall.) 386, 390 (1798) (opinion of Chase, J.). We conclude that the Exclusionary Rule Reform Act is not an ex post facto statute as applied in this case and that as a result, the Defendant s motion to suppress the evidence against him was not well-taken. In addition, we conclude that the Defendant s issues regarding the sufficiency of the evidence to convict him and to sentence him to life without the possibility of parole do not entitle him to relief. Accordingly, the judgments of the Court of Criminal Appeals are affirmed on the separate grounds stated herein.