Supreme Court Allows New Trial for Jury to Receive Proper Instruction on False Imprisonment

August 12, 2013

In a unanimous opinion, the Tennessee Supreme Court has granted a new trial for Terrance Antonio Cecil on a charge of false imprisonment, holding that the trial court did not provide appropriate instruction to the jury as required by the Court’s recent ruling in State v. White. The Court upheld Cecil’s conviction for assault.

In 2010, Columbia police officers responded to a call from Cecil’s Maury County residence, where they found Cecil’s fiancée, Robyn Robledo, in a back bedroom with swelling on her eye, shoulder, and temple. After questioning Cecil and the victim, the police arrested Cecil for domestic assault and false imprisonment.

At trial, the victim admitted she had driven to Cecil’s residence to confront him about his possible infidelity. She provided conflicting accounts as to who initiated the physical altercation, whether she had injured Cecil during the fray, and whether she had more than one opportunity to leave the residence.

After the jury convicted Cecil of assault and false imprisonment, the trial judge expressed doubts about the result, observing that because the assault and false imprisonment charges were “so intertwined,” the evidence “might not justify a separate conviction … for the … false imprisonment aspect,” and adding that “there might not have been a holding or detaining against the victim’s will.”

One year after the trial, while Cecil was waiting for his case to be heard by the Court of Criminal Appeals, the Supreme Court issued its decision in State v. White, which requires, as a matter of constitutional due process, that a jury fully understand the definition of false imprisonment. The ruling distinguishes between whether the removal or confinement of a victim was a “substantial interference” with the victim’s liberty, which would merit a separate conviction, and whether the removal or confinement was merely “incidental” to a crime such as assault, which would not merit a separate conviction.

Although the Court of Criminal Appeals affirmed the convictions for both assault and false imprisonment, the Supreme Court disagreed, ruling that in order to meet standards of constitutional due process, the jury had to be instructed in accordance with White. Because “the proof at trial could be interpreted in different ways,” and because it was “impossible to determine beyond a reasonable doubt whether there was a removal or confinement of the victim that was not essentially incidental to the assault,” a new trial was ordered on the charge of false imprisonment.

Cecil remains convicted of assault and is subject to the six-month sentence for that offense.

To read the State of Tennessee v. Terrance Antonio Cecil Opinion authored by Chief Justice Gary R. Wade, visit TNCourts.gov.