State of Tennessee v. Paul Dennis Reid, Jr.

Summary

The Tennessee Supreme Court affirmed Paul Dennis Reid, Jr.'s convictions for two counts of first degree murder and especially aggravated robbery in the 1997 execution-style killings of two Captain D's employees, and affirmed the death sentences on each murder plus a consecutive twenty-five-year term for the robbery. The Court held that identification testimony resting on the witnesses' coincidental television viewing of Reid's arrest involved no state action and thus raised no due process problem, that search warrants 146 and 149 were valid on particularity, nexus/staleness, service, and affidavit-incorporation grounds, that the circumstantial proof pointed unerringly at Reid alone, and that the trial court properly denied a mistrial after a prosecutor's cross-examination strayed into an unproved prior robbery. It further upheld admission of victim impact evidence under State v. Nesbit against ex post facto and undue-prejudice challenges, deemed the improper penalty-phase prosecutorial argument harmless, and completed statutory proportionality review, finding the death sentences neither arbitrary nor disproportionate. Justice Birch concurred in the affirmance of the convictions but dissented from the death sentences, contending the Court's comparative proportionality review fails its statutory obligation, and would reverse the sentences and remand for resentencing.