State of Tennessee v. James Riels

The appellant, James Riels, appeals his sentences of death imposed by a Shelby County Criminal Court jury. On September 18, 2003, a Shelby County Grand Jury charged the appellant with one count of first degree felony murder for the death of Mary Jane Cruchon, one count of first degree premeditated murder for the death of Mary Jane Cruchon, one count of first degree felony murder for the death of Franchion Pollack, one count of first degree premeditated murder for the death of Franchion Pollack, one count of especially aggravated robbery of Franchion Pollack, one count of attempted especially aggravated robbery of Mary Jane Cruchon, and one count of aggravated burglary of the habitation of Mary Jane Cruchon. On August 9, 2004, the appellant entered guilty pleas to all seven counts. The trial court merged the felony murder convictions with the premeditated murder convictions, resulting in two convictions for first degree murder. A jury was impaneled for the sentencing phase, and on August 13, 2004, the jury imposed the death penalty for the murder of each victim. In the death of Mary Jane Cruchon, the jury unanimously found the presence of three statutory aggravating circumstances. In the death of Franchion Pollack, the jury unanimously found the presence of four statutory aggravating circumstances. The jury further determined that the aggravating circumstances outweighed any mitigating circumstances. The trial court approved the sentencing verdict. In a separate sentencing hearing, the trial court imposed an effective thirty-five-year sentence for the remaining noncapital convictions. The appellant appeals, presenting for our review the following issues: (1) whether the trial court erred by overruling his motion to suppress, (2) whether the trial court erred by permitting the State to cross-examine him regarding the circumstances of the offenses, (3) whether the trial court erred by permitting the introduction of a post-mortem photograph of one of the victims, (4) whether the trial court’s instruction that the appellant’s prior offenses were offenses whose statutory elements involved the use of violence violated the United States Constitution, (5) whether the trial court’s instruction on victim impact evidence constituted a coercive jury instruction, and (6) whether Tennessee’s death penalty scheme is unconstitutional. Finding no errors requiring reversal, we affirm the appellant’s sentences of death.