State of Tennessee v. Aaron James

Summary

The Tennessee Supreme Court held that the names and nature of a defendant's prior felonies are relevant evidence of the prior-conviction element of felony escape and that the State may refuse a defendant's offer to stipulate, but that when proving that status element is the sole purpose of the evidence and the defendant offers to stipulate, Rule 404(b)(3) bars the evidence because its probative value is outweighed as a matter of law by the risk of unfair prejudice. Adopting the substantive rationale of Old Chief while rejecting its federal procedural framework, the Court further held that admission of James's prior convictions — similar to the charged offenses — was not harmless because the proof of his criminal responsibility for his accomplice's conduct was less than overwhelming. The Court affirmed the Court of Criminal Appeals and remanded for a new trial on aggravated robbery and especially aggravated kidnapping. No separate writings were filed.