Tennessee Supreme Court Holds Trial Court Committed Reversible Error In Allowing Improper Impeachment Of Defense Witness, Clarifies Standard Of Review For Speedy Trial Violations

April 20, 2022

The Tennessee Supreme Court today held that the standard of appellate review for an alleged speedy trial violation is de novo with deference to the trial court’s factual findings. The Court also concluded that the trial court committed reversible error in allowing improper impeachment of a key defense witness at trial.  

In December 2017, Defendant William Eugene Moon was involved in a physical altercation with a police officer. The details of the tussle are disputed, but the officer stated that he believed Defendant tried to use deadly force against him, and consequently, the officer shot Defendant. Defendant was transported to a hospital for medical treatment, and upon his release the following month, he was served an arrest warrant.

In April 2018, a Coffee County grand jury indicted Defendant for attempted first-degree murder and unlawful employment of a firearm during the commission of a dangerous felony, among other charges. At a court appearance on May 9, 2018, Defendant requested a trial date, and later that month, he received one. The trial was originally scheduled for November 2018; however, at the State’s request, the court moved the trial date to February 2019 due to an unavoidable scheduling conflict with another case.

At trial, the defense called eyewitness Larry Woods who described observing the altercation from close range. Mr. Woods testified that he did not observe Defendant holding a gun. On cross-examination, the State sought to impeach the witness by questioning him about whether he sold methamphetamine out of his trailer. Mr. Woods’ invoked his Fifth Amendment right against self-incrimination.

The jury convicted Defendant of the lesser-included offense of attempted second-degree murder and of the unlawful employment of a firearm, and he received a sixteen-year sentence. Defendant appealed his conviction asserting, among other things, that he had been denied the right to a speedy trial and that the trial court erred by allowing the improper impeachment of Mr. Woods.  The Court of Criminal Appeals affirmed the judgments of the trial court.

The Supreme Court granted Defendant’s application for permission to appeal to consider whether the Court of Criminal Appeals applied the proper standard of review to Defendant’s claim that he was denied a speedy trial, to address the merits of his speedy trial claim, and to determine whether the trial court committed reversible error in allowing improper impeachment of a defense witness. First, the Court explained that a speedy trial violation claim is, by nature, a mixed question of law and fact, and consequently, it held that the standard of review is de novo with deference to the trial court’s findings of fact unless the evidence preponderates otherwise. The Court then considered the merits of Defendant’s speedy trial claim and determined that, even when viewed under this standard, the Defendant was not denied a speedy trial.

The Supreme Court next considered Defendant’s argument that the Court of Criminal Appeals, after concluding that the trial court erred in allowing the State to impeach Mr. Woods by prior bad acts, should not have found that the error was harmless. The Supreme Court agreed that the impeachment was improper. However, the Court disagreed with the intermediate court’s harmless error analysis. The Court concluded that the improper impeachment of Mr. Woods more probably than not affected the judgment. It, therefore, reversed the judgment of the Court of Criminal Appeals, vacated the judgments of the trial court, and remanded the case to the trial court for further proceedings.

To read the unanimous opinion in State v. William Eugene Moon, authored by Chief Justice Roger A. Page, visit the opinions section of TNCourts.gov.