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Justia Daily Opinion Summaries

Tennessee Supreme Court
February 24, 2021

Table of Contents

State v. Scott

Civil Rights, Constitutional Law, Criminal Law

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Tennessee Supreme Court Opinions

State v. Scott

Docket: M2018-01852-SC-R11-CD

Opinion Date: February 23, 2021

Judge: Page

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

The Supreme Court reversed the judgment of the court of criminal appeals dismissing Defendant's appeal and dismissed Defendant's convictions for possession with the intent to deliver more than twenty-six grams of methamphetamine and possession of drug paraphernalia, holding that the initial search of Defendant's house during which law enforcement discovered illegal contraband was unlawful. Defendant pled guilty but specifically reserved a certified question of law pertaining to the legality of the search in this case. The court of criminal appeals dismissed the appeal, determining that the certified question was not dispositive because the evidence would have been admissible notwithstanding the search in question under the inevitable discovery doctrine. The Supreme Court reversed and dismissed Defendant's convictions, holding (1) the inevitable discovery doctrine did not apply in this case; and (2) the State did not carry its burden of proving that either exigent circumstances or voluntary consent justified their warrantless search of Defendant's home.

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