State of Tennessee v. Charlotte Lynn Frazier and Andrea Parks

Summary

The Tennessee Supreme Court held that, absent interchange, designation, appointment, or another lawful basis, a circuit court judge lacks jurisdiction to issue search warrants for property outside the judge’s statutorily assigned judicial district. The court concluded that the warrants issued by a 23rd Judicial District judge for residences in the 19th Judicial District were constitutionally invalid and that the good-faith exception to the exclusionary rule did not apply. The court affirmed the Court of Criminal Appeals’ judgment upholding suppression of the seized evidence.

Holdings

1. Absent interchange, designation, appointment, or another lawful means of obtaining expanded jurisdiction, a Tennessee circuit court judge lacks authority to issue a search warrant for property located outside the judge's statutorily assigned judicial district.
2. The search warrants issued for the defendants' residences were invalid because the issuing judge lacked geographical jurisdiction, rendering the searches constitutionally invalid under the Fourth Amendment and article I, section 7 of the Tennessee Constitution.
3. The good-faith exception recognized in Tennessee did not apply to searches conducted under warrants issued by a circuit court judge who exceeded his statutory geographical jurisdiction.

Questions Presented

1. Whether Tennessee Rule of Criminal Procedure 41 and Tennessee Code Annotated section 40-1-106 authorized a 23rd Judicial District circuit court judge acting as a magistrate to issue search warrants for property located in the 19th Judicial District.
2. Whether the good-faith exception to the exclusionary rule applied to searches conducted under warrants issued by a judge lacking geographical jurisdiction.

Disposition

affirmed