State of Tennessee v. Zachary Rye Adams

The Defendant, Zachary Rye Adams, was convicted of first degree premeditated murder; two counts of first degree felony murder; two counts of especially aggravated kidnapping, a Class A felony; and three counts of aggravated rape, a Class A felony, by a Hardin County Circuit Court jury after a change of venue. See T.C.A. §§ 39-13-202 (2018) (subsequently amended) (first degree murder); 39-13-305 (2018) (especially aggravated kidnapping); 39- 13-502 (2018) (subsequently amended) (aggravated rape). The State sought the death penalty. However, after the jury returned guilty verdicts, the parties agreed to consecutive sentences of life imprisonment without the possibility of parole for first degree murder, twenty-five years for especially aggravated kidnapping, and twenty-five years for aggravated rape, for an effective sentence of life imprisonment without the possibility of parole plus fifty years. On appeal, the Defendant contends that (1) the evidence is insufficient to support his convictions, (2) the trial court erred by denying a motion to recuse, (3) the trial court erred by granting the State’s motion to disqualify an attorney from the defense team, (4) the trial court erred by admitting evidence in violation of Tennessee Rule of Evidence 404(b), (5) the trial court erred by excluding a prior inconsistent statement, (6) the trial court erred by admitting hearsay evidence, (7) the trial court erred by excluding impeachment evidence, (8) the trial court erred by excluding “witness reactive conduct evidence,” (9) the trial court erred by failing to strike testimony from an undisclosed witness, and (10) the cumulative error doctrine entitles him to relief. We affirm the judgments of the trial court.