Dixon two-part test (Tennessee) · Go Syfert
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Dixon two-part test in Tennessee

20 Tennessee opinions name it 2 courts 2003–2016 0 in the last five years

The cases below were cited by Tennessee courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
State v. Fullergreen
tenn · 2005 · cited in 7 Tennessee opinions naming this issue, 2003–2012
2 sentences

2012We subsequently applied Dixon in, among other cases, State v. Cozart, 54 S.W.3d 242, 247 (Tenn.2001) 4 and State v. Fuller, 172 S.W.3d 533, 537-38 (Tenn.2005). 5 In Richardson , we explicitly recognized the Dixon two-part test as a replacement for the Anthony “essentially incidental” analysis. 251 S.W.3d at 443 .

2008As we previously have observed, the Dixon test “provides the structure necessary for applying the principles announced in Anthony.” State v. Fuller, 172 S.W.3d 533, 537 (Tenn.2005). 5 Although we adhere to the due process principles adopted in Anthony, 6 we now make clear that the Anthony analysis should not be used in conjunction with the Dixon two-part test.

77
State v. Richardsongreen
tenn · 2008 · cited in 14 Tennessee opinions naming this issue, 2009–2016
2 sentences

2016In State v. Dixon, 957 S.W.2d 532, 535 (Tenn. 1997), also in the context of kidnapping, the supreme court replaced the essentially incidental test with a two-part due process analysis which examined whether the confinement went beyond that necessary to perpetrate the underlying felony and whether the kidnapping “(1) prevented the victim from summoning help; (2) lessened the defendant‟s risk of detection; or (3) created a significant danger or increased the victim‟s risk of harm.” (citing Anthony, 817 S.W.2d at 306 ); see State v. Richardson, 251 S.W.3d 438, 443 (Tenn. 2008) (“The Dixon two-par

2015In State v. Richardson, 251 S.W.3d 438, 443 (Tenn.2008), the Court explicitly recognized the Dixon two-part test as a replacement for the Anthony “essentially incidental” analysis.

614
State v. Dixonred
tenn · 1997 · cited in 3 Tennessee opinions naming this issue, 2011–2016
2 sentences

2016In State v. Dixon, 957 S.W.2d 532, 535 (Tenn. 1997), also in the context of kidnapping, the supreme court replaced the essentially incidental test with a two-part due process analysis which examined whether the confinement went beyond that necessary to perpetrate the underlying felony and whether the kidnapping “(1) prevented the victim from summoning help; (2) lessened the defendant‟s risk of detection; or (3) created a significant danger or increased the victim‟s risk of harm.” (citing Anthony, 817 S.W.2d at 306 ); see State v. Richardson, 251 S.W.3d 438, 443 (Tenn. 2008) (“The Dixon two-par

2011Finally, the Dixon court emphasized that the focus of any Anthony inquiry should be on “the purpose of the removal or confinement and not the distance or duration.” Id. -3- In State v. Richardson, 251 S.W.3d 438 (Tenn. 2008), our supreme court completely abandoned the “essentially incidental” analysis of Anthony and replaced it with the two-part test established in Dixon: The Dixon two-part test fully replaces the Anthony “essentially incidental” analysis.

23
State v. Dentonred
tenn · 1996 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016In State v. Denton, 938 S.W.2d 373, 381 (Tenn. 1996), also in a kidnapping context, the supreme court developed a four-part analysis pursuant to double jeopardy principles.

11
State v. Whitegreen
tenn · 2012 · cited in 1 Tennessee opinions naming this issue, 2015–2015
1 sentence

2015See State v. Dixon, 957 S.W.2d 532 (Tenn. 1997), overruled, State v. White, 362 S.W.3d 559 (Tenn. 2012).

11
State v. Cozartgreen
tenn · 2001 · cited in 1 Tennessee opinions naming this issue, 2012–2012
1 sentence

2012We subsequently applied Dixon in, among other cases, State v. Cozart, 54 S.W.3d 242, 247 (Tenn.2001) 4 and State v. Fuller, 172 S.W.3d 533, 537-38 (Tenn.2005). 5 In Richardson , we explicitly recognized the Dixon two-part test as a replacement for the Anthony “essentially incidental” analysis. 251 S.W.3d at 443 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
State v. Anthony red
tenn · 1991
1 sentence

2016In State v. Dixon, 957 S.W.2d 532, 535 (Tenn. 1997), also in the context of kidnapping, the supreme court replaced the essentially incidental test with a two-part due process analysis which examined whether the confinement went beyond that necessary to perpetrate the underlying felony and whether the kidnapping “(1) prevented the victim from summoning help; (2) lessened the defendant‟s risk of detection; or (3) created a significant danger or increased the victim‟s risk of harm.” (citing Anthony, 817 S.W.2d at 306 ); see State v. Richardson, 251 S.W.3d 438, 443 (Tenn. 2008) (“The Dixon two-par

12016–2016
Blockburger v. United States green
scotus · 1931
1 sentence

2003W e held in Anthony that the Blockburger double jeopardy test was not adequate to resolve the issue of whether a separate kidnapping conviction may be imposed because “[t]he essential elements of kidnapping and robbery are obviously separate and distinct, and simultaneous convictions on these two charges would not necessarily violate the rule in Blockburger.” Id. (continued...) 5 should not be used in conjunction with the Dixon two-part test.

12003–2003

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 39-13-305 (12) TN § Tenn. Code Ann. § 39-13-302 (11) TN § Tenn. Code Ann. § 40-35-115 (7) TN § Tenn. Code Ann. § 39-13-303 (6) TN § Tenn. Code Ann. § 39-13-401 (6) TN § Tenn. Code Ann. § 39-12-101 (5) TN § Tenn. Code Ann. § 40-35-103 (5) TN § Tenn. Code Ann. § 40-35-113 (5) TN § Tenn. Code Ann. § 40-35-114 (5) TN § Tenn. Code Ann. § 40-35-210 (5) TN § Tenn. Code Ann. § 40-35-401 (5) TN § Tenn. Code Ann. § 39-13-402 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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