State of Tennessee v. Charles Edgar Ledford

The defendant, Charles Edgar Ledford, appeals from the Monroe County Criminal Court to challenge via certified questions of law his guilty-pleaded convictions of two counts of sexual exploitation of a minor, see T.C.A. § 39-17-1003, a Class D felony; child neglect, see id. § 39-15-402(a), a Class E felony; two counts of aggravated sexual battery, see id. § 39-13-504, a Class B felony; and two counts of rape of a child, see id. § 39-13-522, a Class A felony. The defendant received an effective sentence of 56 years to be served in the Department of Correction. The certified questions relate to law enforcement officers’ discovery and seizure of child pornography materials in the defendant’s house, which had been condemned for demolition by the City of Sweetwater. Upon our review, we hold that the certified questions are not dispositive of some of the convictions, and we dismiss the appeal relative to those convictions. As to the remainder of the convictions, including those for aggravated sexual battery and rape of a child, we hold that the defendant had no expectation of privacy in the seized materials and that the motion to suppress was properly denied. Thus, we affirm the trial court’s order with respect to these latter convictions.