Dotson v. State
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The Supreme Court affirmed the judgment of the post-conviction court denying Petitioner's petition for post-conviction relief, holding that the provisions of Tenn. Sup. Ct. R. 13 are constitutional as applied, that Petitioner was not unconstitutionally denied appellate review of the denial of his request for expert funds, and that Petitioner was not deprived of a full and fair post-conviction hearing.
Petitioner requested funds under Rule 13 to hire expert witnesses to assist in his post-conviction proceedings and, as to the four instances at issue on appeal, the post-conviction court authorized the funds. The Director of the Administrative Office of the Courts and the Chief Justice, however, either reduced the requested amount or denied approval of the funds. Petitioner continued without assistance of the witnesses, and was denied post-conviction relief. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the provisions of Rule 13 for prior approval review are constitutional as applied; (2) Petitioner was not unconstitutionally denied appellate review of the post-conviction court's denial of his expert funds request; and (3) Petitioner was not deprived of a fair post-conviction hearing due to the denial of expert funds.
Court Description: Authoring Judge: Justice Sarah K. Campbell
Trial Court Judge: Special Judge James C. Beasley, Jr.
This appeal involves a capital post-conviction petitioner’s expert funding requests under
Tennessee Supreme Court Rule 13. A jury convicted the Petitioner, Jessie Dotson, of six
counts of premeditated first-degree murder and sentenced him to death. This Court
affirmed the jury’s verdict. The Petitioner filed for post-conviction relief, alleging several
grounds of ineffective assistance of counsel. He requested funds under Tennessee Supreme
Court Rule 13 to hire expert witnesses to assist in establishing his claims of ineffective
assistance of counsel. The post-conviction court authorized the funds, but the Director of
the Administrative Office of the Courts (AOC) and the Chief Justice denied approval for
some of the Petitioner’s requested experts. After an evidentiary hearing, the
post-conviction court denied relief. The Court of Criminal Appeals affirmed the ruling
without deciding the Petitioner’s Rule 13 constitutional challenges. We granted review to
consider the Petitioner’s constitutional issues regarding Rule 13. We hold the provisions
of Rule 13 are constitutional as applied; the Petitioner was not unconstitutionally denied
appellate review of the denial of his request for expert funds; and the Petitioner was not
deprived of a full and fair post-conviction hearing due to the denial of expert funds.
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