Jessie Dotson v. State of Tennessee (Denial of Appellate Remedy)

Style: Jessie Dotson v. State of Tennessee

TSC Docket Number: W2019-01059-SC-R11-PD

Date of TSC Opinion:  July 7, 2023

Opinion of the TSC: Click here.

TSC Summary of the Opinion:

This appeal involves a capital post-conviction petitioner’s expert funding requests under Tennessee Supreme Court Rule 13. A jury convicted the Petitioner, Jessie Dotson, of six counts of premeditated first-degree murder and sentenced him to death. This Court affirmed the jury’s verdict. The Petitioner filed for post-conviction relief, alleging several grounds of ineffective assistance of counsel. He requested funds under Tennessee Supreme Court Rule 13 to hire expert witnesses to assist in establishing his claims of ineffective assistance of counsel. The post-conviction court authorized the funds, but the Director of the Administrative Office of the Courts (AOC) and the Chief Justice denied approval for some of the Petitioner’s requested experts. After an evidentiary hearing, the post-conviction court denied relief. The Court of Criminal Appeals affirmed the ruling without deciding the Petitioner’s Rule 13 constitutional challenges. We granted review to consider the Petitioner’s constitutional issues regarding Rule 13. We hold the provisions of Rule 13 are constitutional as applied; the Petitioner was not unconstitutionally denied appellate review of the denial of his request for expert funds; and the Petitioner was not deprived of a full and fair post-conviction hearing due to the denial of expert funds.

Court of Criminal Appeals Opinion: https://www.tncourts.gov/sites/default/files/dotsonjessieopn_0.pdf

Summary by the Court of Criminal Appeals:

The Petitioner, Jessie Dotson, appeals the post-conviction court’s denial of his postconviction petition, in which he challenged his six convictions for first degree premeditated murder and three convictions for attempted first degree murder and his resulting sentences of death for each of the first degree murder convictions plus 120 years. On appeal, the Petitioner contends that (1) he received ineffective assistance of counsel at trial and on appeal; (2) the Administrative Office of the Courts (“AOC”) and the Chief Justice of the Tennessee Supreme Court improperly vacated the post-conviction court’s orders granting the Petitioner’s request for funding of experts; (3) the convictions and death sentences were the result of juror misconduct; (4) the State and the trial court committed various errors; (5) the Petitioner’s convictions and death sentences and Tennessee’s execution method are unconstitutional; and (6) cumulative error warrants relief. Upon reviewing the record, the parties’ briefs and oral arguments, and the applicable law, we affirm the judgment of the post-conviction court.

Permission to Appeal Granted: October 25, 2022

Appellants’ Briefs Filed: January 27, 2023

Appellees’ Briefs Filed: February 27, 2023

Appellants’ Reply Brief Filed: March 22, 2023

Appellees’ Reply Brief Filed:

Amicus Briefs Permitted:  

Oral Argument Date: April 5, 2023

Link to Oral Argument Video: https://www.youtube.com/watch?v=WYXC2801j2w