State of Tennessee v. Prince Adams

Summary

The Supreme Court of Tennessee affirmed Prince Adams's conviction for first degree premeditated murder and life sentence. The court held that an improper note from a discharged alternate juror to the jury foreman created a presumption of prejudice, but that the State rebutted the presumption under Tennessee Rule of Evidence 606(b).

Holdings

1. A communication from a discharged alternate juror to a deliberating jury member is an improper outside influence that triggers a rebuttable presumption of prejudice, but the State may rebut that presumption through admissible evidence and an objective analysis of the circumstances. Here, the State rebutted the presumption, and the communication did not require a new trial.
2. The trial court erred by admitting a portrait-style photograph of the victim taken while she was alive because the photograph was not relevant to a disputed issue, but the error was harmless. The trial court did not abuse its discretion by admitting the crime-scene photographs because they were relevant to the victim's injuries, the disposal of the body, and premeditation, and their probative value was not substantially outweighed by unfair prejudice.
3. The trial court did not abuse its discretion by admitting the audiotape, including the reference to Adams's prior domestic-violence offense, because the recording was highly probative of his motive and state of mind and the trial court complied with Tennessee Rule of Evidence 404(b).
4. The trial court did not err by refusing to give a special instruction expressly using the term diminished capacity because the general instructions adequately permitted the jury to consider whether Adams's mental condition or Ambien use affected his ability to form the required culpable mental state.
5. The evidence was sufficient for a rational jury to find beyond a reasonable doubt that Adams intentionally and premeditatedly killed Flowers, supporting the first degree murder conviction.

Questions Presented

1. Whether an improper communication from a discharged alternate juror to the jury foreman created a presumption of prejudice and required a new trial.
2. Whether the trial court's admission of a portrait photograph of the victim and crime-scene photographs was reversible error.
3. Whether the trial court abused its discretion by admitting an audiotape containing a reference to Adams's prior domestic-violence offense.
4. Whether the trial court erred by refusing to give a special jury instruction expressly using the term diminished capacity.
5. Whether the evidence was sufficient to establish premeditation and support Adams's conviction for first degree premeditated murder.

Disposition

affirmed