State v. Miller
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The Supreme Court affirmed Defendant's conviction of premeditated murder, first-degree felony murder, and other crimes and his sentence of death but reversed the portion of the judgment of the court of criminal appeals vacating the application of the felony murder aggravating circumstance, holding that the trial court properly convicted and sentenced Defendant.
The court of criminal appeals affirmed Defendant's convictions and sentences but vacated the application of the felony murder aggravating circumstance as to the felony murder conviction. The Supreme Court reversed the portion of the intermediate court's judgment that vacated the application of the felony murder aggravating circumstances to the felony murder conviction, holding (1) the trial court did not err by either removing or failing to remove prospective jurors for cause during individual voir dire based on their view on the death penalty; (2) there was sufficient evidence to support Defendant's convictions; (3) there was no error in the trial court's evidentiary rulings; and (4) Defendant's challenges to his death sentence were unavailing.
Court Description:
Authoring Judge: Chief Justice Roger A. Page
Trial Court Judge: Judge Donald H. Allen
A Madison County jury convicted the defendant, Urshawn Eric Miller, of first-degree premeditated murder and first-degree felony murder for fatally shooting a convenience store employee during an attempted robbery of the store. The jury also convicted the defendant of the attempted second-degree murder of another store employee and of attempted especially aggravated robbery, aggravated assault, employing a firearm during the commission of a dangerous felony, evading arrest, and resisting arrest. The jury imposed the death penalty for the first-degree murder convictions. The trial court merged the felony murder conviction into the premeditated murder conviction and the aggravated assault conviction into the attempted second-degree murder conviction, and it imposed an effective thirty-year sentence for the remaining convictions to run concurrently with the death sentence. The Court of Criminal Appeals affirmed the convictions and sentences but vacated the application of the felony murder aggravating circumstance as to the felony murder conviction. Upon our automatic review, we conclude: (1) the trial court properly ruled on challenges to certain jurors for cause during individual voir dire; (2) the evidence was sufficient to establish the defendant’s identity as the perpetrator and his guilt of the convicted offenses; (3) the trial court did not abuse its discretion by allowing the State to introduce a video recording of the defendant’s prior aggravated robbery during the penalty phase; (4) the death penalty generally, and lethal injection specifically, do not constitute cruel and unusual punishment; and (5) the death sentence satisfies our mandatory review pursuant to Tennessee Code Annotated section 39-13-206. Accordingly, we affirm the defendant’s convictions and sentence of death; however, we reverse the portion of the intermediate court’s judgment vacating the application of the felony murder aggravating circumstance.
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