State of Tennessee v. John F. Curran, III

The Defendant, John F. Curran, III, appeals his Hardin County convictions for passing a worthless check and filing a false lien, for which he received a total effective sentence of five years in the Tennessee Department of Correction. On appeal, the Defendant argues that: (1) the State failed to establish territorial jurisdiction because the offenses took place on federal property; (2) the trial court erred by denying the Defendant’s motion to recuse; (3) the trial court erred by denying defense counsel’s motion to withdraw when counsel explained he lacked knowledge and experience in federal maritime law and admiralty jurisdiction; (4) the trial court violated the Defendant’s due process rights by initially granting his pretrial motion to present affirmative defenses but later ruling those defenses could not be presented to the jury; (5) the evidence was insufficient to support the Defendant’s conviction for passing a worthless check because the payment was for a pre-existing debt and not to induce services; (6) the State committed two Brady1 violations when it failed to disclose evidence proving the State lacked jurisdiction over the case, which led to false testimony from State witnesses; and (7) the trial court erred by imposing a sentence other than the statutory minimum and by imposing an illegal sentence when it failed to cite the victims for each count, failed to order restitution for passing a worthless check, and took no action to remove the lien from the property at issue. After review, we affirm.