State of Tennessee v. Jerry Lewis Tuttle

Summary

The Tennessee Supreme Court overruled State v. Jacumin and adopted a totality-of-the-circumstances analysis for determining probable cause under article I, section 7 of the Tennessee Constitution. Applying that standard, the Court upheld the search warrant, reinstated the defendant’s conspiracy convictions, and affirmed the forfeiture of cash seized during the search on separate grounds.

Holdings

1. The court overruled State v. Jacumin insofar as it retained the rigid Aguilar/Spinelli test and adopted the Illinois v. Gates totality-of-the-circumstances analysis for determining whether a search-warrant affidavit establishes probable cause under article I, section 7 of the Tennessee Constitution.
2. The affidavit provided a substantial basis for finding probable cause to search the 4571 Dugger Road property.
3. The affidavit did not contain false statements that required invalidation of the warrant.
4. The evidence was sufficient to support Tuttle's conviction for conspiracy to possess more than 300 pounds of marijuana with intent to sell.
5. The evidence was sufficient to support Tuttle's conviction for conspiracy to commit money laundering.
6. The cash seized from the 4571 Dugger Road property was subject to judicial forfeiture, and the notice of seizure sent by certified mail satisfied statutory requirements.

Questions Presented

1. Whether the search-warrant affidavit established probable cause under article I, section 7 of the Tennessee Constitution.
2. Whether Tennessee should continue to apply the Aguilar/Spinelli test, rather than the Gates totality-of-the-circumstances test, to probable-cause determinations for search warrants.
3. Whether allegedly inaccurate statements in the affidavit required exclusion of information or invalidation of the warrant.
4. Whether the trial evidence was sufficient to support convictions for conspiracy to possess more than 300 pounds of marijuana with intent to sell or deliver and conspiracy to commit money laundering.
5. Whether the cash seized during execution of the search warrant was subject to judicial forfeiture and whether the State's notice complied with the forfeiture statute.

Disposition

reversed_and_remanded