State of Tennessee, Appellee v. Mack Edward Brown, Appellant

Summary

In a capital case, the Tennessee Supreme Court reversed Mack Edward Brown's first-degree murder conviction for the beating death of his four-year-old son, holding the state failed to prove premeditation and deliberation, and modified the conviction to second-degree murder with a remand for resentencing. The court restored the traditional separation of the elements — deliberation requires a cool purpose free of passion and cannot be formed in an instant — expressly overruled Houston and Martin to the extent they treated 'repeated blows' as sufficient, abandoned much of LaChance's rationale for prolonged-child-abuse prosecutions, and overruled Capps insofar as it suggested a child's conduct could supply adequate provocation for voluntary manslaughter. The court sustained the trial court's consent search, warrant, final Mirandized statement, discovery order (calling it overbroad but not reversibly erroneous), jury selection, evidentiary admissions, and instructions, while concluding the trial judge erred in suppressing the initial hospital statement because Brown was not in custody under Miranda. Sanity and relative parental responsibility were resolved for the state as expert-conflict and credibility questions governed by the jury's verdict.