Today, the Tennessee Supreme Court vacated the second-degree murder convictions of Antonio Demetrius Adkisson, holding that his confession was involuntary and should not have been admitted at trial.
In 2017, then seventeen-year-old Mr. Adkisson was charged with two counts of first-degree murder in the fatal shootings of two juvenile victims at an apartment complex in Milan, Tennessee. Following a transfer hearing, the Gibson County Juvenile Court transferred Mr. Adkisson to circuit court for prosecution as an adult. Before trial, Mr. Adkisson moved to suppress statements he made during a police interrogation conducted during the early to mid-morning hours following the shootings, arguing that the statements were unlawfully obtained. The trial court denied the motion, and the statements were introduced at trial. A jury later convicted Mr. Adkisson of two counts of second-degree murder. In a split decision, the Court of Criminal Appeals affirmed the convictions on direct appeal.
The Tennessee Supreme Court granted review to consider whether the juvenile court properly transferred Mr. Adkisson for adult prosecution and whether his incriminating statements were properly admitted into evidence. The Court upheld the transfer decision and also held that Mr. Adkisson knowingly and voluntarily waived his right to remain silent under the Fifth Amendment of the United States Constitution and Miranda v. Arizona, 384 U.S. 436 (1966) before speaking with investigators.
However, the majority concluded that, under the totality of the circumstances, Mr. Adkisson’s confession was involuntary because it was the product of coercion. As a result, the Court held that admitting the confession at trial violated the Fifth and Fourteenth Amendments of the United States Constitution, as well as Article I, Section 9 of the Tennessee Constitution. The Court therefore vacated Mr. Adkisson’s convictions and remanded the case to the Gibson County Circuit Court for further proceedings.
Justice Sarah Campbell concurred in part and dissented in part. Although she agreed that Mr. Adkisson was properly transferred to adult court and validly waived his Miranda rights, she disagreed with the majority’s conclusion that his confession was involuntary. Applying the same totality-of-the-circumstances analysis, Justice Campbell concluded that Mr. Adkisson’s confession was not unconstitutionally coercive. Consequently, she would have affirmed the denial of Mr. Adkisson’s suppression motion and his convictions.
To read the Supreme Court’s opinion in State of Tennessee v. Antonio Demetrius Adkisson, authored by Chief Justice Jeff Bivins, and the separate opinion of Justice Sarah Campbell, visit the opinions section of tncourts.gov.