State of Tennessee v. Tyrome Cameron Ferguson

The Defendant, Tyrome Cameron Ferguson, was charged by a Monroe County grand jury
with two counts of aggravated assault and one count of reckless endangerment with a
deadly weapon relating to an alleged road-rage incident. On the first day of the Defendant’s
trial, the trial court found that the State had violated Tennessee Rule of Criminal Procedure
16 and declared a mistrial. In a subsequent hearing, the trial court ordered the State to pay
defense counsel $500 “as a contribution toward his attorney[’s] fees” as a sanction for its
discovery violation. The Defendant’s charges were ultimately dismissed by agreement.
The State thereafter filed both an application for extraordinary appeal pursuant to
Tennessee Rule of Appellate Procedure 10 and a petition for common law writ of certiorari
challenging the trial court’s assessment of $500. We denied the State’s application for an
extraordinary appeal but granted its petition for writ of certiorari. State v. Ferguson, No.
E2025-00044-CCA-WR-CO (Tenn. Crim. App. Apr. 1, 2025) (Order). Finding that the
trial court’s order violated the State of Tennessee’s sovereign immunity from suit, we grant
certiorari and reverse and vacate the trial court’s order.