severance hearing (Tennessee) · Go Syfert
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severance hearing in Tennessee

14 Tennessee opinions name it 3 courts 1998–2026 3 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
Spicer v. Stategreen
tenn · 2000 · cited in 7 Tennessee opinions naming this issue, 2007–2026
2 sentences

2024Spicer, 12 S.W.3d at 445 (concluding that “because the trial court’s decision of whether to consolidate offenses is determined from the evidence presented at the hearing, appellate courts should usually only look to that evidence”); see also Shirley, 6 SW.3d at 247 (reviewing severance issue by examining only the proof at the severance hearing where the trial court held a severance hearing but failed to make findings of fact and conclusions of law); cf. Toliver, 331 S.W.3d at 404 (stating that because trial court failed to hold a hearing, our supreme court analyzed the consolidation issue base

2008In Spicer , we characterized the relevancy portion of the severance inquiry as a determination of whether "evidence of each offense is relevant to some material issue in the trial of all the other offenses.” Spicer, 12 S.W.3d at 445 (emphasis added) (citing Tenn. R.

47
State v. Shirleygreen
tenn · 1999 · cited in 2 Tennessee opinions naming this issue, 2022–2024
2 sentences

2024Spicer, 12 S.W.3d at 445 (concluding that “because the trial court’s decision of whether to consolidate offenses is determined from the evidence presented at the hearing, appellate courts should usually only look to that evidence”); see also Shirley, 6 SW.3d at 247 (reviewing severance issue by examining only the proof at the severance hearing where the trial court held a severance hearing but failed to make findings of fact and conclusions of law); cf. Toliver, 331 S.W.3d at 404 (stating that because trial court failed to hold a hearing, our supreme court analyzed the consolidation issue base

2024Spicer, 12 S.W.3d at 445 (concluding that “because the trial court’s decision of whether to consolidate offenses is determined from the evidence presented at the hearing, appellate courts should usually only look to that evidence”); see also Shirley, 6 SW.3d at 247 (reviewing severance issue by examining only the proof at the severance hearing where the trial court held a severance hearing but failed to make findings of fact and conclusions of law); cf. Toliver, 331 S.W.3d at 404 (stating that because trial court failed to hold a hearing, our supreme court analyzed the consolidation issue base

12
State v. Mooregreen
tenn · 1999 · cited in 1 Tennessee opinions naming this issue, 2022–2022
1 sentence

2022Under the first prong, Tennessee recognizes three categories of a common scheme or plan: (1) “signature crimes,” (2) “offenses that are part of a larger, continuing plan or conspiracy,” and (3) “offenses that are all part of the same criminal transaction.” Dotson, 254 S.W.3d at 387 , n.6 (citing Shirley, 6 S.W.3d at 248 ); see also State v. Moore, 6 S.W.3d 235, 240 (Tenn. 1999).

11
Darryl F. Bryant, Sr. v. Darryl F. Bryant, Jr.green
tenn · 2017 · cited in 1 Tennessee opinions naming this issue, 2019–2019
1 sentence

2019In Bryant, the Tennessee Supreme Court “join[ed] the majority of jurisdictions in following the common-law doctrine of severance and [held] that a joint tenancy with an express right of survivorship may be severed and the estate thereby turned into a tenancy in common, by any one of the joint owners, at his will.” Id. at 411 (internal -3- Thereafter, construction began on the Shelby Drive property for an office building and a very large shop building (nearly the size of a football field) to be used by Shelby Railroad.

11
Goad v. Stategreen
tenn · 1996 · cited in 1 Tennessee opinions naming this issue, 2017–2017
1 sentence

2017Goad v. State, 938 S.W.2d 363, 370 (Tenn. 1996). - 14 - A. Trial Preparation The Petitioner argues that trial counsel was ineffective in failing to adequately meet with the Petitioner, failing to interview Mr. Mathis prior to trial, and failing to properly enter letters written by Mr. Mathis as exhibits during the severance hearing.

11
State v. Burchfieldgreen
tenn · 1984 · cited in 1 Tennessee opinions naming this issue, 1998–1998
1 sentence

1998P., mandates that a severance of permissively joined offenses be granted unless “the offenses are part of a common scheme or plan and the evidence of one would be admissible upon the trial of the others.” Because the “primary inquiry into whether a severance should have been granted under Rule 14 is whether the evidence of one crime would be admissible in the trial of the other if the two counts of the indictment had been severed,” see State v. Burchfield, 664 S.W.2d 284, 286 (Tenn. 1984), we believe that our standard of review of a trial court’s denial of a severance under the rule is the sam

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 (6)

CaseCitedYears
State v. Hallock green
tenncrimapp · 1993
1 sentence

2022Id. at 289-90 .

12022–2022
State v. Dotson green
tenn · 2008
1 sentence

2022Under the first prong, Tennessee recognizes three categories of a common scheme or plan: (1) “signature crimes,” (2) “offenses that are part of a larger, continuing plan or conspiracy,” and (3) “offenses that are all part of the same criminal transaction.” Dotson, 254 S.W.3d at 387 , n.6 (citing Shirley, 6 S.W.3d at 248 ); see also State v. Moore, 6 S.W.3d 235, 240 (Tenn. 1999).

12022–2022
Albro v. Allen green
mich · 1990
1 sentence

2017JUR. 2d Cotenancy and Joint Ownership §§ 21-22 (2015); Allen, supra, at 918 , § 2; see also Tindell, 37 S.W. at 1106.

12017–2017
State v. Johnson green
tenn · 2011
2 sentences

2013On appeal, the State cites State v. Johnson, 342 S.W.3d 468 (Tenn. 2011), in support of its argument that joinder was mandatory because “the defendant’s crimes occurred in a close sequence of time and were ‘inextricably connected.’” At the severance hearing, the State argued similarly that the offenses were “interlocked together” and that the offenses were part of “one criminal episode.” The State relied on the defendant’s statement to Mr. Holloway, Ms. Wade’s alleged telephone call to Mr. Goins shortly before her murder, and the defendant’s use of Ms. Wade’s car to drive to the location of th

2013The evidence adduced at the severance hearing established that Ms. Wade was murdered in the Bordeaux area of Nashville at approximately 8:20 p.m., but Mr. Goins was murdered in a separate location some 15 to 20 minutes away at approximately 9:35 p.m. -15- Thus, although the offenses were committed within a relatively short period of time, they were not committed “simultaneously or in close sequence” and did not “occur in the same place or in closely situated places.” See Johnson, 342 S.W.3d at 475 .

12013–2013
Strickland v. Washington green
scotus · 1984
1 sentence

2005Strickland, 466 U.S. at 688 ; Baxter, 523 S.W.2d at 936 .

12005–2005
Baxter v. Rose green
tenn · 1975
1 sentence

2005Strickland, 466 U.S. at 688 ; Baxter, 523 S.W.2d at 936 .

12005–2005

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 40-35-210 (7) TN § Tenn. Code Ann. § 40-35-113 (6) TN § Tenn. Code Ann. § 40-35-114 (6) TN § Tenn. Code Ann. § 40-35-102 (5) TN § Tenn. Code Ann. § 40-35-103 (5) TN § Tenn. Code Ann. § 40-35-115 (5) TN § Tenn. Code Ann. § 40-35-401 (5) TN § Tenn. Code Ann. § 40-35-112 (3)

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.

Where else courts name it

AZ 102 (1975–2026) CA 44 (1951–2026) TX 35 (1957–2022) WA 14 (1990–2026) TN 14 (1998–2026) IL 13 (1949–2016) OH 12 (2001–2022) MN 11 (1990–2026) NY 11 (1976–2008) PA 11 (2010–2026) KS 10 (1991–2020) FL 9 (1971–2018) MO 9 (2007–2021) MS 7 (1995–2009) GA 6 (1981–2025) AR 5 (1968–2016) WI 5 (1987–2022) NC 5 (1986–2002) WV 4 (1983–2023) ND 4 (1990–2023) MI 3 (1989–2025) NJ 3 (1985–2013) LA 3 (1960–2014) NV 3 (2009–2013) AL 3 (1972–2006) UT 3 (1996–2022) NH 3 (2016–2022) CT 3 (2009–2025) RI 2 (1887–1994) DC 2 (1978–2005) CO 2 (1982–2026) NM 2 (1971–2011) OR 2 (2013–2016) VT 2 (2006–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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