State of Tennessee v. Steven Ray Thacker

Summary

A jury convicted Steven Ray Thacker of first degree premeditated murder and felony murder for the January 2, 2000 stabbing of Dyersburg wrecker operator Ray Patterson, killed after Thacker's attempt to pay for a tow with a stolen credit card was rejected, and a capital sentencing jury imposed death on the avoidance-of-arrest and fleeing-a-felony aggravators. On automatic appeal, the Supreme Court affirmed the Court of Criminal Appeals' judgment, finding the evidence sufficient on cause of death, premeditation, and felony murder; deeming the exclusion of hearsay mitigation testimony and the missing limiting instruction harmless errors; upholding the limitation of forensic psychiatrist Dr. Keith Caruso's testimony as within the trial court's discretion; rejecting a specific instruction on a non-statutory 'history of abuse and neglect' mitigator as neither constitutionally required nor fairly raised by the evidence; validating reliance on the avoidance-of-arrest aggravator even where the arrest feared involved unrelated out-of-state warrants; and concluding through mandatory comparative proportionality review that the death sentence was neither arbitrary nor disproportionate. Justice Birch concurred in affirming the conviction but dissented from the death sentence, renewing his position that the Court's comparative proportionality protocol is inadequate to shield defendants from arbitrary or disproportionate imposition of capital punishment.