State of Tennessee v. Jeremy Reynolds (First Degree Murder; Gang Issues, Evidence Issues) DECIDED NOVEMBER 29, 2021

Style: State of Tennessee v. Jeremy Reynolds

TSC Docket Number: E2018-01732-SC-R11-CD

Date of TSC Opinion: November 29, 2021 (eight months after oral argument).

Decision of the Tennessee Supreme Court:  https://www.tncourts.gov/sites/default/files/e2018-01732-sc-r11-cd_-_majority_opinion.pdf

Summary of Decision of the Tennessee Supreme Court:

Jeremy Reynolds was convicted of premeditated first-degree murder at the conclusion of a jury trial in which the State was permitted to introduce evidence related to gang membership. On appeal, the Court of Criminal Appeals concluded that the evidence of premeditation was legally insufficient and reversed the conviction.  The intermediate appellate court noted that the evidence was legally sufficient to support a conviction for the lesser-included offense of second-degree murder, but it nevertheless remanded for a new trial based on its determination that the trial court had abused its discretion in admitting certain pieces of evidence related to gang membership. We accepted the State’s appeal.  After a thorough review of the record, we conclude that the evidence was legally sufficient to support the conviction for premeditated first-degree murder. We further conclude that there was no reversible error on the part of the trial court in admitting evidence related to gang membership. Accordingly, we reverse the decision of the Court of Criminal Appeals and reinstate Reynolds’s conviction for premeditated first-degree murder.

Court of Criminal Appeals Decision: https://www.tncourts.gov/sites/default/files/jeremy_reynolds_corrected_opinion.pdf

Court of Criminal Appeals Summary:

The Defendant, Jeremy Reynolds, appeals his Hamilton County Criminal Court jury conviction for first degree premeditated murder. See Tenn. Code Ann. § 39-13-202. On appeal, the Defendant argues that (1) the evidence was insufficient to support his conviction; (2) the trial court erred by admitting evidence that the Defendant and other individuals were gang members in violation of Tennessee Rules of Evidence 403 and 404(b); (3) exculpatory evidence, namely the victim’s gunshot residue test and a photograph referenced by the gang report, were improperly withheld by the State; (4) the trial court erred by failing to compel the State to produce the above-referenced gunshot residue test and photograph; and (5) the cumulative effect of these errors deprived the Defendant of a fair trial. After a thorough review of the record and applicable law, we conclude that the evidence is insufficient relevant to premeditation and that some of the evidence relative to gangs was improperly admitted. We remand for a new trial on one count of second-degree murder, in which some gang evidence shall be excluded.

Pre-argument Briefing:

Appellant:  December 16, 2020

Appellee:  February 14, 2021

Appellant’s Reply: March 1, 2021

Appellee’s Reply: March 15, 2021

Oral Argument Date:  March 31, 2021

Link to Oral Argument Video: https://www.youtube.com/watch?v=wkGwPEDF2Ps