State of Tennessee v. William Eugene Moon (Attempted Murder and Unlawful Employment of a Firearm; Improper Impeachment; Speedy Trial) DECIDED APRIL 20, 2022

Style: State of Tennessee v. William Eugene Moon

TSC Docket Number: M2019-01865-SC-R11-CD

Date of TSC Opinion: April 20, 2022

Decision of the Tennessee Supreme Court: 

https://www.tncourts.gov/sites/default/files/moon_william_eugene-_filed_opn.pdf

Summary of Decision of the Tennessee Supreme Court: 

William Eugene Moon (“Defendant”) was convicted of attempted second degree murder and unlawful employment of a firearm during the commission of or attempt to commit a dangerous felony. Defendant appealed his conviction and asserted, among other things, that he had been denied the right to a speedy trial and that the trial court erred by allowing improper impeachment of a defense witness. The Court of Criminal Appeals affirmed the judgments of the trial court, holding that Defendant was not denied a speedy trial and, although the trial court erred in allowing the prosecution to improperly impeach a defense witness, the error was harmless. This Court granted Defendant’s application for permission to appeal to consider whether the Court of Criminal Appeals applied the proper standard of review to Defendant’s claim that he was denied a speedy trial, to address the merits of Defendant’s speedy trial claim, and to determine whether the trial court committed reversible error in allowing improper impeachment of a defense witness. We hold that the standard of review for an alleged speedy trial violation is de novo with deference to the trial court’s findings of fact unless the evidence preponderates otherwise. When reviewed under this standard, we determine that the Court of Criminal Appeals properly held that the Defendant was not denied a speedy trial. Further, we agree with the intermediate court that the trial court erred in allowing improper impeachment of a defense witness. However, we hold that this error was not harmless and is reversible error. Accordingly, we reverse the judgment of the Court of Criminal Appeals and vacate the judgments of the trial court. The case is remanded to the trial court for further proceedings consistent with this opinion.

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

Court of Criminal Appeals Summary:

A Coffee County jury convicted William Eugene Moon, Defendant, of attempted second degree murder and unlawful employment of a firearm during the commission of or attempt to commit a dangerous felony. On appeal, Defendant argues that the trial court erred by allowing the improper impeachment of a defense witness, that there was insufficient evidence to support his convictions, and that he was denied the right to a speedy trial. After a thorough review of the record and applicable case law, the judgments of the circuit court are affirmed.

Pre-argument Briefing:

Appellant:  June 14, 2021

Appellee:  August 12, 2021

Appellant’s Reply: September 2, 2021

Oral Argument Date:  October 6, 2021

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