Payne v. State
Annotate this CaseIn 1998, Petitioner was convicted of two counts of first-degree murder and sentenced to death. Petitioner subsequently pursued collateral review without success. In 1990, the Tennessee General Assembly passed legislation providing that no defendant with an intellectual disability at the time of committing first-degree murder shall be sentenced to death. In 2012, Petitioner filed a motion to reopen his petition for postconviction relief, arguing that he was intellectually disabled within the meaning of the intellectual disability statute. Thereafter, the Supreme Court issued its decision in Keen v. State, in which the Court held that Coleman v. State did not provide a basis for reopening a postconviction proceeding in order to assess a capital defendant’s claim of intellectual disability. Petitioner subsequently filed an amended petition for relief from death sentences seeking relief pursuant to the error coram nobis statute and the intellectual disability statute. The trial court denied the motion to reopen and amended petition without holding an evidentiary hearing. The Court of Criminal Appeals affirmed. The Supreme Court affirmed, holding that the procedural avenues by which Petitioner was seeking relief in this proceeding did not entitle him to the hearing he sought.
Court Description: Authoring Judge: Justice Jeffrey S. Bivins
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