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State v. Ronald Rickman
Citation: Not availableDocket: 02C01-9608-CR-00252
Court: Court of Criminal Appeals of Tennessee; July 28, 1997; Tennessee; State Appellate Court
Original Court Document: View Document
The court's decision involves Ronald Rickman's post-conviction appeal concerning his conviction for first-degree murder in Shelby County. A concurring opinion expresses agreement with the majority's conclusion but contests its interpretation regarding jury unanimity and the felony murder doctrine. The majority contends that the jury was instructed solely on premeditated and deliberate murder, asserting no issue related to the felony murder doctrine exists since the indictment and instructions did not suggest otherwise. However, the concurring opinion argues that the jury was indeed presented with the felony murder issue during the trial. It cites precedents indicating that a conviction for first-degree murder can arise from felony murder, even if the indictment specifies premeditated murder. The concurring opinion highlights that the complete jury instructions allowed for a finding of first-degree murder based on the appellant's actions during the commission of rape, robbery, or kidnapping, thus providing the jury with multiple avenues for conviction under the relevant statutory definitions. The opinion emphasizes the need for clarity on the implications of the jury's options and the legal context surrounding the definitions of murder and related felonies. To establish first-degree murder, the killing must be willful, deliberate, malicious, and premeditated, meaning a deliberate design to kill must exist prior to the act, even if only briefly. The critical factor is the mental state of the slayer at the time of the killing, specifically whether they were free from excitement or passion to premeditate the act. The trial court's failure to provide the jury with the complete statutory definition of first-degree murder does not negate the possibility of felony murder, as the jury found beyond a reasonable doubt that the murder occurred during the commission of a felony (rape, robbery, or kidnapping). The case references Schad v. Arizona, which suggests that premeditated murder and felony murder are alternative means of achieving first-degree murder, and unanimity among jurors regarding the method is not essential under federal law. However, under state law, the jury's agreement on whether the murder was premeditated impacts sentencing. Despite this, the evidence indicated that the appellant committed a premeditated and deliberate murder, affirming the dismissal of the post-conviction petition.