State of Tennessee v. Joseph Ray Daniels

The Defendant, Joseph Ray Daniels, confessed to the beating death of his five-year-old son, Joseph Clyde Daniels III, and was convicted by a jury of second-degree murder, first-degree felony murder, aggravated child abuse, making a false police report, and tampering with evidence.  He subsequently received an effective sentence of life imprisonment.   In this appeal, the Defendant argues the trial court erred in denying his motion to suppress his confession (1) because the State failed to corroborate his extrajudicial confession under the modified trustworthiness standard outlined in State v. Bishop, 431 S.W.3d 22 (Tenn. 2014), and (2) because his post-polygraph video recorded statement was obtained by law enforcement through coercive interrogation techniques including an express promise of leniency.  The Defendant also argues the trial court abused its discretion in failing to exclude as hearsay utterances by the victim’s three-year-old brother, “Joe dead, Joe dead, Joe dead,” and the response of his aunt, “Yes baby, Joe dead;” and in failing to exclude as not relevant and unfairly prejudicial Facebook messages his wife exchanged with a paramour leading up to the victim’s death.  We affirm.