State of Tennessee v. Janet Michelle Stanfield, Tony Alan Winsett and Justin Bradley Stanfield

An Obion County grand jury indicted Tony Alan Winsett, Janet Michelle Stanfield, and Justin Bradley Stanfield for multiple drug and weapons charges based on the warrantless search of their home and the subsequent automobile stop involving defendants Winsett and Janet Stanfield.  The defendants filed motions to suppress the evidence against them based on an allegedly improper search.   Following a suppression hearing, the trial court granted the defendants’ motions and dismissed the charges against them.  The Court of Criminal Appeals affirmed the trial court’s ruling.  The State then filed an application for permission to appeal to this Court.  See Tenn. R. App. P. 11(a).  We granted the State’s application and, upon review, hold that, with respect to defendants Winsett and Janet Stanfield, the warrantless search of the residence was constitutionally permissible based on defendant Winsett’s status as a parolee and the doctrine of common authority.  However, we conclude that the warrantless search with respect to defendant Justin Stanfield was constitutionally unreasonable because he retained a reasonable expectation of privacy in his bedroom and the State failed to carry its burden of proving that defendant Winsett exercised common authority over Justin Stanfield’s bedroom.  Accordingly, we affirm in part, reverse in part, and remand to the trial court for further proceedings consistent with this opinion.