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State of Tennessee v. Darius Montez Edwards

Citation: Not availableDocket: M2008-01219-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; October 20, 2009; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case concerns the criminal proceedings against a defendant who was indicted for premeditated first-degree murder and attempted first-degree murder at the age of sixteen. His case was transferred from juvenile to criminal court, where he eventually pled guilty to facilitation of first-degree murder and facilitation of attempted first-degree murder, resulting in a sentence of twenty-four years and eleven years, respectively, to be served concurrently. During sentencing, the trial court considered various enhancement and mitigating factors in accordance with the 2005 amendments to the Tennessee sentencing act. The defendant appealed, challenging the trial court's designation of him as a leader in the crimes. The appellate court conducted a de novo review, affirming the trial court's judgment and holding that the enhancement factors, including the defendant's leadership role, justified the sentences imposed. The court's decision emphasized adherence to Tennessee's sentencing guidelines and the proper application of enhancement and mitigating factors, ultimately denying the defendant relief and upholding the concurrent twenty-four-year sentence.

Legal Issues Addressed

Appellate Review of Sentencing

Application: The appellate court conducted a de novo review of the sentencing, affirming the trial court's decision based on the presumption of correctness.

Reasoning: The appellate review is de novo, with a presumption of correctness regarding the trial court's determinations.

Enhancement and Mitigating Factors in Sentencing

Application: The trial court considered various enhancement factors, including the defendant's leadership role and use of a firearm, while applying one mitigating factor.

Reasoning: The court applied several enhancement factors, including the defendant's leadership role in the offense, the use of a firearm, the infliction of serious bodily injury, and prior juvenile delinquency that would qualify as a felony if committed by an adult.

Role of Leadership in Criminal Offenses

Application: The trial court determined that the Appellant played a leadership role in the crimes, a finding upheld by the appellate court despite the Appellant's contestation.

Reasoning: Appellant contests the trial court's classification of him as a leader in the offense... The appellate court concludes that the trial court's determination of Appellant as a leader is supported by the evidence.

Sentencing Principles under Tennessee Law

Application: The trial court applied the 2005 amendments to the sentencing act, considering enhancement and mitigating factors in sentencing the Appellant.

Reasoning: The trial court applied the 2005 amendments to the sentencing act and identified multiple enhancement factors from Tennessee Code Annotated section 40-35-114 relevant to the Appellant's case.

Transfer of Juvenile to Criminal Court

Application: The case involved the transfer of a sixteen-year-old defendant from juvenile court to criminal court for trial on serious charges.

Reasoning: At sixteen years old, his case was moved from juvenile to criminal court.