State of Tennessee v. Kemontea Dovon McKinney

A Robertson County jury convicted Kemontea Dovon McKinney (“Defendant”), a juvenile at the time of the offenses, of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. The trial court merged the murder convictions and merged the theft conviction into the aggravated robbery conviction. The trial court imposed a life sentence for the murder conviction and eight years for the aggravated robbery conviction. This appeal concerns whether Defendant’s pretrial statement to detectives was voluntary, whether Defendant validly waived his Miranda rights, and whether the evidence was sufficient to support his conviction for premeditated first-degree murder. The trial court denied Defendant’s motion to suppress and admitted Defendant’s pretrial statement into evidence. The Court of Criminal Appeals reversed. We granted the State’s application for permission to appeal to consider whether the intermediate court erred when it stated that an involuntary confession claim is “inextricably linked” to a Miranda-waiver claim, such that the two inquiries can be considered together. We also granted the State’s application to consider whether the Court of Criminal Appeals erred in determining that the evidence was insufficient to support Defendant’s conviction for premeditated first-degree murder. After review, we conclude that the Court of Criminal Appeals erred with respect to the issues raised by the State. We reiterate that the voluntariness test is distinct from the test for Miranda waiver, despite similarities between the analyses. After separately considering both questions, we conclude that Defendant’s overall statement was voluntary and his Miranda waiver was both knowing and voluntary. Additionally, we conclude that the evidence presented by the State was sufficient to support Defendant’s conviction for premeditated first-degree murder. We reverse the decision of the Court of Criminal Appeals and reinstate the trial court’s judgments.