Evidence, Chain of Custody
Unless otherwise indicated, all indented material is copied directly from the court’s opinion.
Decisions of the Tennessee Supreme Court
Decisions of the Tennessee Court of Criminal Appeals
State v. Spencer, No. E2022-00350-CCA-R3-CD, p. 6-7 (Tenn. Ct. Crim. App. May 8, 2023).
Whether the required chain of custody has been sufficiently established to justify the admission of evidence is a matter committed to the sound discretion of the trial court. Cannon, 254 S.W.3d at 295 (citations omitted). The court’s determination will not be overturned in the absence of a clearly mistaken exercise of that discretion. State v. Holbrooks, 983 S.W.2d 697, 701 (Tenn. Crim. App. 1998) (citing State v. Beech, 744 S.W.2d 585, 587 (Tenn. Crim. App. 1987)).
State v. Spencer, No. E2022-00350-CCA-R3-CD, p. 6-7 (Tenn. Ct. Crim. App. May 1, 2023).
Whether the required chain of custody has been sufficiently established to justify the admission of evidence is a matter committed to the sound discretion of the trial court. Cannon, 254 S.W.3d at 295 (citations omitted). The court’s determination will not be overturned in the absence of a clearly mistaken exercise of that discretion. State v. Holbrooks, 983 S.W.2d 697, 701 (Tenn. Crim. App. 1998) (citing State v. Beech, 744 S.W.2d 585, 587 (Tenn. Crim. App. 1987)).
State v. Bowen, No. E2022-00691-CCA-R3-CD, p. 14 (Tenn. Ct. Crim. App. April 14, 2023).
We review challenges to the chain of custody of evidence under the abuse of discretion standard. State v. Cannon, 254 S.W.3d 287, 294 (Tenn. 2008) (citing State v. Scott, 33 S.W.3d 746, 752 (Tenn. 2000) and State v. Beech, 744 S.W.2d 585, 587 (Tenn. Crim. App. 1987)). Under this standard, we will not reverse unless the trial court “ ‘applied an incorrect legal standard, or reached a decision which is against logic or reasoning that caused an injustice to the party complaining.’” Id. (citations omitted).
State v. Holmes, No. E2021-01489-CCA-R3-CD, p. 13 (Tenn. Ct. Crim. App. Nov. 7, 2022).
“Whether the requisite chain of custody has been established to justify admission . . . is ‘a matter committed to the discretion of the trial judge and [t]his determination will not be overturned in the absence of a clearly mistaken exercise thereof.” Davis v. Shelby Cnty. Sheriff’s Dep’t, 278 S.W.3d 256, 267 (Tenn. 2009) (quoting Shell v. Law, 935 S.W.2d 402, 409 (Tenn. Ct. App. 1996)). Accordingly, this court will not reverse the trial court’s ruling on the chain of custody “unless the trial court ‘applied an incorrect legal standard, or reached a decision which is against logic or reasoning that caused an injustice to the party complaining.’” State v. Cannon, 254 S.W.3d 287, 295 (Tenn. 2008) (quoting State v. Shirley, 6 S.W.3d 243, 247 (Tenn. 1999)).
State of Tennessee v. Dunn, No. E2021-00343-CCA-R3-CD, p. 21-22 (Tenn. Ct. Crim. App. July 5, 2022).
Generally, “questions concerning the admissibility of evidence rest within the sound discretion of the trial court, and this [c]ourt will not interfere in the absence of abuse appearing on the face of the record.” State v. Plyant, 263 S.W.3d 854, 870 (Tenn. 2008). A trial court abuses its discretion when it “applies an incorrect legal standard or reaches a conclusion that is ‘illogical or unreasonable and causes an injustice to the party complaining.’” Id. (citing State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006)).
. . .
We review challenges to the chain of custody of evidence under the abuse of discretion standard. Cannon, 254 S.W.3d at 295 (citing Scott, 33 S.W.3d at 752). Generally, “[a] trial court abuses its discretion when it applies incorrect legal standards, reaches an illogical conclusion, bases its ruling on a clearly erroneous assessment of the proof, or applies reasoning that causes an injustice to the complaining party.” State v. Phelps, 329 S.W.3d 436, 443 (Tenn. 2010).
State v. Daniels, No. E2021-00561-CCA-R3-CD, p. 12 (Tenn. Ct. Crim. App. June 29, 2022).
This Court reviews a trial court’s determination regarding the chain of custody for an abuse of discretion. Id. at 295.
State of Tennessee v. Johnson, No. W2019-01133-CCA-R3-CD, p. 17 (Tenn. Ct. Crim. App. Apr. 18, 2022).
A trial court’s decision to admit evidence based on establishing a chain of custody is reviewed for abuse of discretion. Scott, 33 S.W.3d at 752. This court will not reverse the trial court’s decision to admit evidence unless the court applied an incorrect legal standard or reached a decision which was against logic or reasoning and which caused an injustice to the complaining party. Cannon, 254 S.W.3d at 295.
State of Tennessee v. McDowell, No. E2020-01641-CCA-R3-CD, p. 26 (Tenn. Ct. Crim. App. Apr. 14, 2022).
This court reviews chain of custody determinations for an abuse of discretion. [State v. Cannon, 254 S.W.3d 287,} 295 [Tenn. 2008].
