Byron Black v. State of Tennessee

At the heart of this appeal is a narrow procedural question: whether the 2021 amendment to Tennessee Code Annotated section 39-13-203 permits the Defendant, Byron Black, to move for a hearing on whether he has an intellectual disability and is therefore ineligible for the death penalty. The trial court dismissed the motion after determining that the Defendant was procedurally barred from bringing the issue. On appeal, we hold that because the issue of the Defendant’s intellectual disability has been previously adjudicated, he may not file a motion pursuant to Tennessee Code Annotated section 39-13-203(g)(1). We also hold that the General Assembly’s decision not to entitle the Defendant to a second hearing does not subject him to cruel and unusual punishment, nor does it deny him due process of law or the equal protection of the law. Accordingly, we respectfully affirm the judgment of the trial court.