Tennessee Court Declines Opportunity to Broaden Review

In a 3-2 decision, the Tennessee Supreme Court has maintained the death sentence of Corinio Pruitt as well as the current court standard for proportionality review. Pruitt was sentenced to death for the 2005 murder of 79-year-old Lawrence Guidroz in Memphis, who died a day after he was thrown to the ground by Pruitt who was stealing his car.

The Court is required by state law to review death cases to determine if the sentence is appropriate in comparison to similar cases.  In reviewing Pruitt’s case, the Court first considered whether the current standards should be changed.

Prior to 1997, the Court looked at all cases in which a defendant had been convicted of first-degree murder to see if a death sentence in a particular first-degree murder case was disproportionate to the sentences of those convicted of similar crimes. In 1997, the Court decided that it would only compare cases in which the defendant was sentenced to death to other cases in which a death sentence was sought, drastically limiting the pool of cases for consideration.

In their dissent, Justice William C. Koch and Justice Sharon G. Lee stated that comparing all first-degree murder cases would be more consistent with Tennessee law and with the standard that capital punishment should be reserved for the most heinous murders. These Justices agreed with the 2007 American Bar Association’s assessment of Tennessee’s death penalty, which asserted that limiting the pool of cases for comparison undercuts the whole reason for proportionality review.

The dissenting Justices also argued that a sentence of life without parole would be more appropriate for Pruitt given that the death penalty should be reserved for the most dangerous criminals.

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Photo by Salfalko

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