State of Tennessee v. Tony Thomas and LaRonda Turner

A jury convicted two defendants, Tony Thomas and Laronda Turner, of three counts of
first-degree premeditated murder. Those convictions stem from a triple homicide that
occurred in Memphis, Tennessee, in 2015. Another co-defendant, Demarco Hawkins, was
also implicated in the killings. However, his trial was severed from the other defendants,
and he testified against Mr. Thomas and Ms. Turner. After Mr. Thomas and Ms. Turner
were convicted, they appealed to the Court of Criminal Appeals, raising five issues for
review. The intermediate appellate court ruled unanimously on three of the issues, but one
judge dissented on the other two. Mr. Thomas and Ms. Turner sought permission to appeal,
and we accepted the appeal only as to the two issues on which the intermediate appellate
court was divided. First, we agreed to consider whether the prosecution breached the
requirements of Brady v. Maryland, 373 U.S. 83 (1963), by failing to produce statements
made by Mr. Hawkins at proffer conferences, which were allegedly inconsistent with Mr.
Hawkins’ formal statement to law enforcement, before trial. Second, we agreed to address
whether the evidence was sufficient to support Ms. Turner’s murder convictions. Based
on our review, we conclude that the State did not breach its obligations under Brady with
regard to Mr. Thomas. Additionally, we determine that the evidence is insufficient to
sustain Ms. Turner’s convictions because Mr. Hawkins’ testimony was not adequately
corroborated.1 As a result, we affirm the decision of the Court of Criminal Appeals in part
and reverse in part. Additionally, in this opinion, we abrogate Tennessee’s common law
accomplice-corroboration rule. However, we apply that change on a prospective basis
only, and, thus, it has no bearing on the outcome of this case.