The Tennessee Supreme Court has affirmed the convictions and sentences of death for Lemaricus Devall Davidson for the murders of Channon Christian and Christopher Newsom in Knoxville.
In January 2007, Mr. Davidson and others abducted Ms. Christian and Mr. Newsom outside of an apartment complex in north Knoxville. Mr. Davidson stole Ms. Christian’s vehicle, forced her and Mr. Newsom into the vehicle, and took them to his house. The victims were robbed, kidnapped, raped, and murdered.
Mr. Newsom’s burned and partially nude body was found the next day beside railroad tracks not far from Mr. Davidson’s home. Mr. Newsom had been brutally raped and shot three times. On the third day, Ms. Christian’s vehicle was found down the street from Mr. Davidson’s house, and police discovered a bank envelope in the back seat of her vehicle that revealed Mr. Davidson’s fingerprint.
The following day, police obtained a search warrant for Mr. Davidson’s house and, while searching the house, discovered Ms. Christian’s body stuffed in a garbage can in the kitchen. After being beaten and repeatedly raped, a plastic bag had been tied around Ms. Christian’s head and face, and she suffocated to death. Mr. Davidson’s palm prints and fingerprints were found on three of the five garbage bags that contained Ms. Christian’s body. Personal items belonging to Ms. Christian and Mr. Newsom were found in Mr. Davidson’s home. After the murders, Mr. Davidson gave some of Ms. Christian’s clothing to his girlfriend and had Mr. Newsom’s athletic shoes with him when he was arrested.
In October 2009, a Knox County jury convicted Mr. Davidson of multiple counts of first degree felony murder, first degree premeditated murder, especially aggravated robbery, aggravated kidnapping, aggravated rape, facilitation of aggravated rape, and theft of property. The jury imposed two sentences of death for Mr. Davidson. In 2015, the Court of Criminal Appeals affirmed the convictions and sentences of death.
Upon review by the Supreme Court as required by law, Mr. Davidson raised many issues, one of which was the legality of the search of his house based on a faulty affidavit. The Knoxville police officer who prepared the affidavit for the search warrant failed to sign it. Neither the general sessions court judge who issued the search warrant nor the assistant district attorney general noticed the omission.
The Supreme Court held that a signed affidavit is required by statutory and procedural rules. Therefore, the warrant was invalid, and under the exclusionary rule, any evidence found as a result of the execution of the warrant, including Ms. Christian’s body, was not admissible at trial. To avoid this harsh result, the Court adopted a limited good-faith exception to the exclusionary rule for a nonconstitutional violation.
The exclusionary rule is a judicially created rule that suppresses evidence obtained as a result of an improper search. A good-faith exception to that rule would allow the jury to consider the evidence when the officer violated a specific statute or rule but did so in good faith and unintentionally.
The narrow exception adopted by the Court would apply when a law enforcement officer has reasonably and in good faith conducted a search within the scope of a warrant the officer believes to be valid but is later determined to be invalid solely because of agood-faith failure to comply with the affidavitrequirement of Tennessee law. Based on the adoption of this rule, the Court held that the items seized during searches of Mr. Davidson’s house and DNA samples taken from him were admissible evidence.
The Court also held that Mr. Davidson’s statement to law enforcement was admissible and that the trial court did not err in letting the jury view Mr. Davidson’s recorded statement in the open courtroom during deliberations. The Court approved the trial court’s decision to allow family members of Ms. Christian and Mr. Newsom to wear buttons during the trial displaying their images. The Court found no error in other rulings of the trial court, including its decision regarding the admissibility of post-death photographs of the victims and testimony from expert witnesses regarding ballistics and fingerprint evidence.
After reviewing all the evidence, the Court concluded that the evidence fully supported Mr. Davidson’s convictions and sentences of death, the sentences were not arbitrary, the aggravating circumstances supporting the sentences outweighed any mitigating circumstances, and the sentences were not disproportionate to sentences imposed in similar cases.
Read the unanimous opinion in State of Tennessee v. Lemaricus Devall Davidson, authored by Justice Sharon G. Lee.