Rogers v. Tennessee

532 U.S. 451 (2000)

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Rogers v. Tennessee

United States Supreme Court
532 U.S. 451 (2000)

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Facts

Wilbert Rogers (defendant) stabbed James Bowdery. After surgery, Bowdery slipped into a coma and never recovered. Bowdery died 15 months after Rogers stabbed him. Rogers was convicted of murder pursuant to Tennessee’s criminal-homicide statute. This statute did not mention the year-and-a-day rule, which was a common-law rule that a defendant could not be convicted of murder unless the victim died within a year and a day of the defendant’s act. The rule originated from earlier skepticism about the capabilities of medical science. Three prior published Tennessee cases had mentioned the rule in dicta, but no published Tennessee judicial opinion had ever relied on the rule in a murder case. Rogers appealed, claiming that the year-and-a-day rule prevented his conviction. The Tennessee Court of Criminal Appeals affirmed the conviction. The Tennessee Supreme Court ruled that the year-and-a-day rule had been a part of Tennessee’s common law but that the original reasons for the rule no longer existed. Several other states had abolished the rule by legislation, and most courts that had considered the rule had abolished it. The Tennessee Supreme Court expressly abolished the rule and affirmed Rogers’s conviction. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

Dissent (Scalia, J.)

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