Tennessee Supreme Court

State of Tennessee, Appellant v. Willie Williams, Jr. Appellee

September 21, 19981998 Tenn. LEXIS 512

Summary

The Tennessee Supreme Court held that the trial court's failure to instruct the jury on voluntary manslaughter was subject to harmless error analysis and, because the jury convicted on the greater offense of first‑degree murder while being instructed on the lesser included offense of second‑degree murder, the error was harmless; the Court also held that the admission of Gloria Buchanan’s testimony was not inadmissible hearsay. The Court reversed the Court of Criminal Appeals and reinstated the trial court’s judgment. A dissent argued that the instruction error violated the constitutional right to a jury trial and required automatic reversal.