Harold Wayne Nichols v. State of Tennessee

Summary

The Supreme Court of Tennessee affirmed the Court of Criminal Appeals' judgment denying post-conviction relief to Harold Wayne Nichols, upholding his felony murder conviction and death sentence for the 1988 rape and murder of Karen Pulley. The court held that trial counsel were not ineffective in any respect alleged — including failure to investigate claimed exculpatory serology, hair, weapon, alibi, and alternative-suspect evidence, failure to challenge the confessions as false, failure to challenge the legality of the arrest, and various penalty-phase omissions — because Nichols's multiple detailed confessions and consistent admissions of guilt reasonably shaped counsel's strategy and no post-conviction evidence established deficiency or a reasonable probability of a different outcome. The court also held that the intermediate court properly refused to remand for additional DNA testing but erred in addressing the petitioner's right against self-incrimination, an issue the State never appealed, though the error had no effect on the result. Justice Birch, concurring in part and dissenting in part, would not concur in the imposition of the death penalty, reiterating his view that comparative proportionality review inadequately shields defendants from arbitrary and disproportionate death sentences.