Claude Francis Garrett was convicted of felony murder in 1993 and sentenced to life imprisonment. His conviction was affirmed on direct appeal, and the Tennessee Supreme Court denied further appeal. Garrett later petitioned for post-conviction relief, which was denied by the trial court in July 1998. He appealed this denial, raising four primary issues: 1) alleged withholding of exculpatory evidence by the State; 2) ineffective assistance of trial counsel; 3) jury misconduct and bias; and 4) constitutional concerns regarding jury instructions on "unreasonable doubt." The appellate court, led by Judge David H. Welles, reversed the trial court's decision and remanded the case for findings of fact and conclusions of law as required by statute.
The background of the case involved the death of Lorie Lance from smoke inhalation during a fire at a residence she shared with Garrett. Upon arrival, firefighters found Garrett had escaped, but Lance was discovered unconscious in a locked utility room, which had boarded windows. Evidence pointed to arson, including traces of kerosene at the scene and a smoke detector with a removed battery. While Garrett suffered burns, his clothing tested negative for accelerants.
An autopsy indicated the victim had a blood alcohol level of .06 percent at the time of death. A neighbor observed the Defendant near a tree during a fire, noting that the Defendant attempted to break windows and called for the victim. The neighbor described the Defendant as having a "cold" demeanor. A firefighter testified that the Defendant claimed to know the victim's location during the fire, directing the firefighter to the back of the house. A police detective noted the Defendant's nervousness post-fire and his inquiry about being under arrest, despite not being accused of arson at that time. The Defendant provided inconsistent accounts of the events on the night of the fire.
Defense firefighters described needing to restrain the allegedly intoxicated Defendant from re-entering the burning home, where he insisted the victim was inside. After being charged, the Defendant was located in Hiawatha, Kansas, where he claimed to be staying with his mother. The Defendant testified about his relationship with the victim, stating they had been together for 1.5 years and had plans to marry. On the night of the fire, they had visited a bar, returned home, and fell asleep on the couch before going to bed. He recounted waking to the fire, calling for the victim, and describing the utility room door as hard to open, not locked. The Defendant mentioned kerosene was stored in the house and that the smoke detector was inoperable due to being taken down for painting and lacking batteries.
Witnesses at the trial highlighted a troubled relationship between the Defendant and victim, with reports of prior abuse and fear expressed by the victim. The Defendant admitted to physically beating the victim on three occasions and had a criminal history that included grand theft and burglaries.
During a post-conviction hearing, Detective David Miller detailed a report discussing the victim's body position when discovered in the utility room, noting it was not locked and was positioned parallel to the outside wall.
Miller testified at the hearing that he remembered having an initial conversation about the case but could not recall specifics beyond what was in his report, which he forwarded to the district attorney’s office. This report was not disclosed to the defense, and no findings of fact were established in the record. Miller discussed a toxicology report revealing that the Defendant had a blood alcohol level of 0.11 percent at the time of the fire, noting that this report should have been sent to the district attorney’s office along with other case documents.
Captain Otis Jenkins testified that he responded to the fire on February 24, 1992, and was likely the first to find the victim's body. Jenkins contradicted Miller's report, asserting that the utility room door was locked when he arrived and maintained that he had never indicated it was unlocked.
Greg Galloway, the Defendant’s trial attorney, testified about his experience and involvement in the case, stating he dedicated at least 150 hours of work and communicated with the Defendant multiple times. They discussed the State's written discovery response and identified about eight witnesses to call at trial. Galloway mentioned that he primarily spoke with Detective Miller by phone, during which Miller claimed the utility room door was not locked. Galloway attempted to contact Jenkins and other firefighters for information but received no responses. He also submitted a discovery request to the assistant district attorney but did not file a copy with the court. Among the documents, Galloway received a house diagram that did not indicate a bedspread found in front of the refrigerator, which surprised him during trial when a firefighter testified about it. He did not cross-examine the witness regarding the diagram, although an evidence log indicated that bed material was recovered from the scene, without mentioning that it was soaked in kerosene.
Galloway testified that prior to trial, Assistant District Attorney General Zimmerman led him to believe there was no evidence of the door being locked, which influenced Galloway's decision not to prepare a defense regarding this issue. He indicated that had he known the State would present evidence about the door being locked, he would have sought to counter that evidence. Galloway acknowledged an oversight in failing to request Jencks Act material, which included Detective Miller's report stating Captain Jenkins believed the outside utility room door was not locked, leaving Galloway without this crucial information during the trial.
During the trial, a violation of the court’s sequestration order occurred when a relative of the victim relayed testimony to potential witnesses outside the courtroom. Galloway did not move for a mistrial due to uncertainty about the seriousness of the conversation and admitted he failed to make an offer of proof regarding the violation. He also stated he was not provided with the toxicology report showing the Defendant had a blood alcohol level of .11% on the night of the fire, which he would have used to explain the Defendant's behavior. However, Galloway conceded that the Defendant had informed him about drinking that night, and he did present this information to the jury.
Zimmerman testified that two diagrams of the residence were provided to the defense, neither showing a bedspread soaked with kerosene in front of the refrigerator, despite the existence of a discovery document noting discrepancies in the sketches. He maintained that the bedspread, which smelled of an accelerant, was shown to Galloway before the trial. Zimmerman also claimed the toxicology report was filed without reaching him, and he confirmed that he interviewed Captain Jenkins about the utility room door, with Jenkins denying he had ever informed Miller that the door was unlocked, asserting that his memory was clear as he was the one who unlatched the door.
Zimmerman testified that he did not view a statement as 'exculpatory information' due to its inaccuracies, noting Detective Miller's vague recollection of a conversation with Captain Jenkins, contrasting it with Jenkins' clarity. The Defendant stated that during nearly a year on bond before trial, he had no substantive discussions with his attorney, Galloway, regarding his defense, claiming they only had a few phone conversations about evidence and that he met Galloway in person only three times. Post-conviction, the trial court denied the petition without providing oral findings or conclusions, which is required by the Post-Conviction Procedure Act. The appellate court highlighted the necessity of the trial court's findings for proper review and remanded the case for the trial court to issue a final order with detailed findings of fact and conclusions of law concerning each ground in the Defendant's petition. The appellate court's ruling reversed the trial court's denial of relief and mandated compliance with statutory requirements, allowing the Defendant to appeal after the trial court's order is entered.
