State v. Pruitt

Decision Date08 October 2013
Docket NumberNo. W2009–01255–SC–DDT–DD.,W2009–01255–SC–DDT–DD.
Citation415 S.W.3d 180
PartiesSTATE of Tennessee v. Corinio PRUITT.
CourtTennessee Supreme Court


Harry E. Sayle, III and Tony N. Brayton, Memphis, Tennessee, for the appellant, Corinio Pruitt.

Robert E. Cooper, Jr., Attorney General and Reporter; William E. Young, Solicitor General; Gordon W. Smith, Associate Solicitor General; James E. Gaylord, Assistant Attorney General; William L. Gibbons, District Attorney General; and Amy P. Weirich, Alanda H. Dwyer, and John W. Campbell, Assistant District Attorneys General, for the appellee, State of Tennessee.

Anne E. Passino and Wade V. Davies, Knoxville, Tennessee; Russell Cass, Daniel Greenfield, and Collin P. Wedel, Los Angeles, California; Eric Grant Osborne, Seema Kakad Jain, and Mary Schmid Mergler, Washington, D.C.; and J. Robin McKinney Jr., Nashville, Tennessee, for the amicus curiae, Tennessee Association of Criminal Defense Lawyers and The Constitution Project.

Allan F. Ramsaur, Jacqueline Belle Dixon, and Paul C. Ney, Nashville, Tennessee, and David Miller Eldridge, Knoxville, Tennessee, for the amicus curiae, Tennessee Bar Association.

Erica Knievel Songer, Kathryn A. Blair, Khang V. Tran, and Thomas N. Bulleit Jr., Washington, D.C., and Dwight L. Aarons, Knoxville, Tennessee, for the amicus curiae, Tennessee Death Penalty Assessment Team.

Mark A. Fulks, Johnson City, Tennessee, and J. Wally Kirby, Nashville, Tennessee, for the amicus curiae, Tennessee District Attorneys Conference.

Anthony J. Dick, Washington, D.C.; Brian J. Murray, Chicago, Illinois; and Jeffrey S. Henry, Nashville, Tennessee, for the amicus curiae, Tennessee District Public Defenders Conference.

JANICE M. HOLDER, J., delivered the opinion of the Court, in which GARY R. WADE, C.J., and CORNELIA A. CLARK, J. joined. WILLIAM C. KOCH, JR., and SHARON G. LEE, JJ., filed a concurring & dissenting opinion.


A jury convicted the defendant of first degree felony murder. The jury imposed a sentence of death based on three aggravating circumstances: (1) the defendant had previously been convicted of one or more felonies involving the use of violence; (2) the murder was knowingly committed while the defendant had a substantial role in committing a robbery; and (3) the victim was seventy years of age or older. SeeTenn.Code Ann. § 39–13–204(i)(2), (7), (14) (2010). The Court of Criminal Appeals affirmed. On automatic appeal pursuant to Tennessee Code Annotated section 39–13–206(a)( l ) (2010), we designated the following issues for oral argument: 1 (1) whether the evidence was sufficient to support the jury's finding of guilt of first degree felony murder beyond a reasonable doubt; (2) whether the trial court erred in determining that the defendant had failed to prove by a preponderance of the evidencethat he was intellectually disabled and thereby ineligible for the death penalty; and (3) whether the sentence of death is disproportionate or invalid pursuant to the mandatory review of Tennessee Code Annotated section 39–13–206(c)( l ). On December 6, 2012, we ordered re-argument on the following issues: (1) whether the proportionality analysis adopted by the majority of the Court in State v. Bland, should be modified; (2) whether the absence of an intent to kill should render the death penalty disproportionate; and (3) whether the pool of cases considered in proportionality analysis should be broadened. Having carefully considered these issues and the other issues raised by the defendant, we find no merit to the defendant's arguments. Accordingly, we affirm the judgment of the Court of Criminal Appeals.

I. Facts and Procedural History

Corinio Pruitt, the defendant, was indicted for first degree premeditated murder and first degree felony murder for the death of Lawrence Guidroz. SeeTenn.Code Ann. § 39–13–202(a)(1), (2) (2007). After a six-day trial, a jury convicted Mr. Pruitt and imposed a death sentence. The Court of Criminal Appeals affirmed the sentence of death. State v. Pruitt, No. W2009–01255–CCA–R3–DD, 2011 WL 2417856, at *41 (Tenn.Crim.App. June 13, 2011). This appeal followed.

A. Evidence at Guilt Phase

On the morning of August 2, 2005, Courtney Johnson encountered Mr. Pruitt by chance as he walked to the Apple Market on Winchester Road in Memphis, Tennessee. Mr. Pruitt talked about stealing a car and asked Mr. Johnson if he would get in the car with him if Mr. Pruitt took one. Although Mr. Johnson told Mr. Pruitt “no,” he remained with Mr. Pruitt outside the market and spoke to people who came to the market, including Mr. Pruitt's cousin, Michael Rockett. Later, Mr. Johnson's friend, “Sed,” came to the market. Mr. Pruitt remained outside the market as Mr. Johnson and Sed walked to the Family Dollar store at the other end of the shopping center. Mr. Johnson testified that he went with Sed to the Family Dollar store because he did not want to be involved in whatever Mr. Pruitt was going to do.

Taka Pruitt 2 arrived at the Apple Market with her neighbor. They parked directly outside the front door of the market. Ms. Pruitt stayed in the car while her neighbor went inside. As she waited in the car, she observed a “younger gentleman,” later identified as Mr. Pruitt, standing to the left of the door. Ms. Pruitt recognized him as someone who lived in her apartment complex. After five or six minutes, Ms. Pruitt saw an older man walk out of the market with groceries in his arms and walk to his car. As he reached the driver's side door, Mr. Pruitt ran up behind the older man and pushed him into the car. Although she could not see clearly into the car, it appeared to Ms. Pruitt that the two men were “tussling.” She saw Mr. Pruitt on top of the older man, and she could see the older man's feet dangling out of the car. After about fifteen seconds, she saw Mr. Pruitt throw the older man to the ground, slam the car door, and drive away. When Ms. Pruitt checked on the victim, he was shaking and having trouble breathing and he was bleeding from his nose and both ears.

Ms. Pruitt ran inside the market, told employees that someone had just been carjacked,3 and asked them to call 911. She then ran back to the victim and called 911 on her cell phone. Ms. Pruitt went to the police station after the carjacking. She identified Mr. Pruitt from a photo lineup as the person who beat the victim and took the victim's car. At trial, Ms. Pruitt was shown a still photo created from the market's security camera video. She circled an image of Mr. Pruitt, identifying him as the younger man she saw push the victim into his car. Ms. Pruitt also confirmed that Mr. Pruitt was alone when he attacked the victim.

Courtney Johnson testified that he saw the victim arrive at the Apple Market in a brown Chevrolet and walk into the market just before he and Sed went to the Family Dollar store. Mr. Johnson said that the victim appeared to be fine when he went into the Apple Market. Mr. Johnson and Sed were in the Family Dollar store for “three to four minutes.” When they walked back in the direction of the Apple Market, Mr. Johnson saw “an old man laying down with blood coming out of his head, and his car was gone.” Mr. Pruitt was also gone. Mr. Johnson said he ran inside the market and asked someone to call 911. He left the scene before the police arrived because he did not want to be involved and did not want to “snitch” on Mr. Pruitt.

Memphis Police Officer Charmell Smith was the first officer on the scene and arrived before emergency medical personnel. She found the victim lying on his back on the ground and bleeding from his ears and mouth. She testified that the victim was “semi-conscious” and that she helped load the victim into an ambulance when it arrived. Based on her prior medical training as a certified nursing assistant, she opined that the bleeding from the ears indicated some kind of head trauma.

Thomas J. Leech III identified the victim, Mr. Lawrence Guidroz, from a still photo created from the Apple Market's security camera video. Mr. Leech testified that he had known Mr. Guidroz for more than twenty-five years and that he was very close to Mr. Guidroz. Mr. Leech went to the hospital to see Mr. Guidroz when he heard that Mr. Guidroz had been attacked. Mr. Leech remained in Mr. Guidroz's hospital room throughout the night. At no point was Mr. Guidroz able to communicate with Mr. Leech. Mr. Guidroz died the next day. Mr. Leech testified that Mr. Guidroz was seventy-nine years old at the time of his death. Mr. Guidroz was buried in Louisiana after a service in Memphis. Mr. Leech identified photographs of Mr. Guidroz's car, bearing the license plate number CUX 845.

Following the carjacking, Memphis Police began looking for the victim's car. Officer Jonas Holguin found the car parked at the Somerset Apartments near Tullahoma and Winchester and was instructed to watch it from a distance. At trial, Officer Holguin was shown the photograph of Mr. Guidroz's car, which had been identified by Mr. Leech, and confirmed that the license plate was the same as the car he was instructed to watch. At some point, the car was moved from the apartment complex without the knowledge of the police, and the police began to search the area in an attempt to locate the car. The car was later observed pulling into a residence at 3180 Beauchamp, and a team of police officers converged on that location.

The driver of the car, who was wearing a red shirt, went inside the house. The police made the decision to apprehend the driver. Mr. Johnson came out of the house and the police took him into custody. According to Sergeant Robin Hulley, Mr. Johnson yelled, “the guy you want is in the back yard.” Officers went to the back yard and saw a man wearing a red shirt jump over a fence and run. Although dogs were called in to track the man, police had no success in finding him.

Mr. Johnson testified that after the incident at the Apple Market, he did not...

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