The Tennessee Supreme Court issued an opinion today holding that Supreme Court Rule 13, which provides the procedure for administering funds appropriated by the Tennessee Legislature for assisting indigent litigants in capital cases, was constitutionally applied in the State’s case against Jessie Dotson. A Shelby County jury convicted Mr. Dotson of six counts of premeditated first-degree murder, and he was sentenced to death. His convictions and sentences were affirmed on appeal.
Mr. Dotson sought post-conviction relief, raising several claims of ineffective assistance of counsel. He requested funds to hire and pay experts to assist him on these claims under a Tennessee statute that provides for investigative or expert services for indigent defendants to ensure their constitutional rights are properly protected. The Tennessee General Assembly annually appropriates a limited amount of funds in capital cases for this purpose.
Supreme Court Rule 13 establishes the procedures defendants must use to request these funds for expert services, and for the Director of the Administrative Office of the Courts’ and the Chief Justice’s administrative review of the authorization of funds. In this case, the post-conviction court authorized the funds requested by Mr. Dotson, but the AOC Director and Chief Justice reduced the amount in some instances and denied approval in others.
Mr. Dotson appealed to the Supreme Court, arguing that Rule 13’s provisions were unconstitutional as applied to him, that he was unconstitutionally denied appellate review of the denial of funds for experts, and that he was denied a full and fair post-conviction hearing. The Supreme Court disagreed, ruling that the application of the Rule 13 procedure to Mr. Dotson’s case was constitutional, that he was not denied due process, and that he was afforded a full and fair post-conviction hearing.
Justice Jeffrey S. Bivins did not participate in this case.
To read the opinion of the Court in Jessie Dotson v. State, authored by Justice Sharon G. Lee, please visit the Opinions section of TNCourts.gov.