State of Tennessee v. Antonio Demetrius Adkisson a/k/a Antonio Demetrius Turner, Jr. - DISSENT

Court of Criminal Appeals of Tennessee·Decided March 25, 2024·No. W2022-01009-CCA-R3-CD·Published

Opinion

03/25/2024

IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON

October 3, 2023 Session

STATE OF TENNESSEE v. ANTONIO DEMETRIUS ADKISSON A/K/A ANTONIO DEMETRIUS TURNER JR.

Appeal from the Circuit Court for Gibson County No. 19840 Clayburn Peeples, Judge

No. W2022-01009-CCA-R3-CD

CAMILLE R. MCMULLEN, P.J., dissenting.

Police officers in this case obtained a confession from a juvenile by threatening him with the death penalty, repeatedly denying his requests for his mother who was present at the station, and interrogating him for over six hours in the middle of the night. After reviewing the totality of the circumstances, I would have concluded that the trial court erred in denying the Defendant’s motion to suppress because the Defendant’s Miranda waiver was invalid and his confession was involuntary. I also would have concluded that the juvenile court erred in finding probable cause that the Defendant committed the offenses. Therefore, I must respectfully dissent.

I. Juvenile Transfer. The juvenile court found probable cause that the Defendant committed two counts of first degree murder based on the following facts presented at the transfer hearing: (1) the Defendant was at the Meadows with the co-defendant two hours before the shooting; (2) the co-defendant interacted with one of the victims and displayed a gun; (3) a witness saw the Defendant and the co-defendant speed walking or running through “the cut” after the shooting; and (4) the victims were shot with two different guns. These facts amount to mere suspicion rather than probable cause.

Appellate review of a lawyer juvenile judge’s order transferring a child to be tried as an adult is “awkward” because it occurs only after there has been a final judgment in the case. State v. Griffin, 914 S.W.2d 564, 566 (Tenn. Crim. App. 1995). In other words, if the juvenile court erred in transferring jurisdiction to the trial court, then appellate review of the issue is held in abeyance until the case is concluded on the merits. This is particularly problematic where, as in this case, a defendant contends that there were insufficient findings of fact in support of probable cause that he committed the offense. If the Defendant’s contention is true, then the State lacked the ability to charge him as an adult,

the jury lacked the authority to consider his guilt, and the trial court lacked the jurisdiction to impose a sentence.

At issue in this case is Tennessee Code Annotated Section 37-1-134(a)(4)(A), which requires that the juvenile court find probable cause to believe that the child committed the delinquent act before transferring that child to criminal court. Probable cause in the context of juvenile transfer hearings is not statutorily defined. In the context of an arrest, probable cause exists when the facts and circumstances and reliable information known to the officer at the time of arrest were “‘sufficient to warrant a prudent [person] in believing that the [individual] had committed or was committing an offense.’” State v. Lawrence, 154 S.W.3d 71, 75-76 (Tenn. 2005) (quoting State v. Bridges, 963 S.W.2d 487, 491 (Tenn. 1997)). “[T]he probable[-]cause standard is ... practical, nontechnical, and focuses upon the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.” State v. Reynolds, 504 S.W.3d 283, 300-01 (Tenn. 2016) (internal citations and quotations omitted). “[T]he strength of the evidence necessary to establish probable cause to arrest is significantly less than the strength of evidence necessary to find a defendant guilty beyond a reasonable doubt.” State v. Bishop, 431 S.W.3d 22, 41 (Tenn. 2014); see also Adams v. Williams, 407 U.S. 143, 149 (1972) (“Probable cause does not require the same type of specific evidence of each element of the offense as would be needed to support a conviction.”). Finally, probable cause must be more than a mere suspicion, but less than absolute certainty. Reynolds, 504 S.W.3d at 300.

Giving deference to the factual findings of the juvenile court, I am unable to conclude that the Defendant was properly transferred to be tried as an adult. It bears mentioning that the juvenile court suppressed the Defendant’s statement and did not consider it at the juvenile transfer hearing. The remaining evidence presented at the transfer hearing does not establish probable cause that the Defendant committed two counts of first-degree murder. First, the State presented no evidence tending to show that the Defendant intended to kill the victims or engaged in premeditation. See Tenn. Code Ann. § 39-13-202(a)(1) (first degree murder is a “premeditated and intentional killing of another”). More importantly, the State presented no evidence from which a reasonable person could infer the Defendant’s identity as the shooter, or that the Defendant was even at the scene of the shooting at the time of the offense. See State v. Rice, 184 S.W.3d 646, 662 (Tenn. 2006) (citing State v. Thompson, 519 S.W.2d 789, 793 (Tenn. 1975)) (“The identity of the perpetrator is an essential element of any crime.”). The testimony that the Defendant was speed walking or running through “the cut” on the night of the offense established only that he was in the vicinity of the shooting after it occurred. But this activity, standing alone, amounts to mere suspicion and not probable cause.

It is significant to my conclusion that the juvenile court heard testimony regarding the co-defendant and the Defendant at the same time. When describing the testimony supporting a finding of probable cause, the juvenile court mentioned the co-defendant

individually no less than five times, and only mentioned the Defendant in joint references to “the defendants.” While there was testimony that earlier that night the co-defendant had a verbal exchange with a group that included one of the victims, and that the co-defendant displayed a gun, no such testimony was offered against the Defendant. This is problematic because “probable cause to arrest and/or search an individual must be particularized to that individual” and “mere proximity to criminal activity alone is insufficient[.]” See, e.g., Whitehead v. Commonwealth, 683 S.E.2d 299, 313 (Va. 2009). Given the lack of proof particularized to the Defendant, the juvenile court erred in finding probable cause that the Defendant committed the offenses. This error means that the trial court lacked jurisdiction to convict and sentence the Defendant. Accordingly, I would have reversed the judgments of the trial court.

II. Motion to Suppress. The trial court admitted a confession obtained: (1) from a juvenile with no prior experience with the police; (2) after over six hours of interrogation in the middle of the night; and (3) after he was improperly threatened with the death penalty and repeatedly denied access to his mother. The totality of the circumstances demonstrates that the Defendant’s Miranda waiver was invalid and his confession was involuntary.

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State of Tennessee v. Antonio Demetrius Adkisson a/k/a Antonio Demetrius Turner, Jr. - DISSENT (State of Tennessee v. Antonio Demetrius Adkisson a/k/a Antonio Demetrius Turner, Jr. - DISSENT) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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