ࡱ> fhea fjbjbYQYQ ~3333LZ666R<  8*!F!< #~!!(!!!!!!r#t#t#t#t#t#t#,y%R'r# !!!!!#B#RV!!#B#B#B#!| ! !r#B# ^R !r#B#B# B# ! C  6" B#N#$#0#B#=)B#=)N#B# d IN THE CIRCUIT COURT FOR BLOUNT COUNTY, TENNESSEE STATE OF TENNESSEE ) ) ) ) vs. ) No. 12721 ) ) REGINALD STACY SUDDERTH ) Defense Motion No.: 107 Motion For Change Of Venue SUPPLEMENTAL MEMORANDUM Pursuant to this Courts Order of June 20, 2001, Defendant files the following supplement to Defense Motion 107: Motion to Change of Venue. This memorandum addresses whether the Court should consider change of venue prior to an attempt to seat a jury in Blount County and reasons why venue should be changed prior to trial to assure Defendant Sudderth a fair trial. Defendant Sudderth asserts that T.R.Crim.P. Rule 21 and T.C.A. 20-4-101 require that undue excitement and prejudicial publicity cause for change of venue considered prior to trial pursuant to a prospective test. In addition, Defendant Sudderth asserts "other cause(s)" exist for changing venue that will not be eliminated by attempting to select a jury in Blount County and that by waiting to attempt to seat a jury will result in undue delay and unnecessary expense. On June 20, 2001, this court granted Defense Motion No. 104: Motion to consider all motions and objections by the defense in light of a higher standard of due process and reliability that attaches in death penalty cases. The heightened standard of due process required because this is a death penalty case is particularly applicable to this motion to change the venue of the trial of this case pretrial. MEMORANDUM Authority for Changing Venue Authority for a change of venue is found in the Fifth and Sixth Amendments to the United States Constitution; Article 1, Section 8 of the Tennessee Constitution; T.R.Crim.P. Rule 21; and T.C.A. 20-4-201. The provisions of the rule and statute are: RULE 21. CHANGE OF VENUE (a) In all criminal prosecutions the venue may be changed upon motion of the defendant, or upon the court's own motion with the consent of the defendant, if it appears to the court that, due to undue excitement against the defendant in the county where the offense was committed or any other cause, a fair trial probably could not be had. 20-4-201. Applicable cases; good cause; special venire of jurors In all civil cases at law where the issue is to be tried by jury, and in all cases of issues in courts of equity directed to be tried by jury, either in the circuit or chancery court, in all civil cases before a judge of the court of general sessions, and in all criminal cases: (1) The venue may be changed, at any time before trial, upon good cause shown, as prescribed in this part; or (2) A court may issue an order for a special venire of jurors from another county if in its discretion it determines the action to be necessary to insure a fair trial. Mr. Sudderth is entitled to receive a fair trial consistent with constitutional due process. Sheppard v. Maxwell, 384 U.S. 333, 86 S.Ct. 1507, 16 L.Ed.2d 600 (1966). "The constitutional standard of fairness requires that a defendant have 'a panel of impartial, indifferent jurors.'" Murphy v. Florida, 421 U.S. 784, 799, 95 S.Ct. 2031, 44 L.Ed.2d 589 (1975), quoting Irvin v. Dowd, 366 U.S. 717, 722, 81 S.Ct. 1639, 6 L.Ed.2d 751 (1961). If a defendant cannot obtain such a jury in the county where the charges are brought, the defendant is constitutionally entitled to a change of venue, see, e.g., Groppi v. Wisconsin, 400 U.S. 505, 510-511, 91 S.Ct. 490, 27 L.Ed.2d. 571 (1971). The prospective test Both the wording of the statute and rule dictate that venue determinations be made prior to trial. T.C.A. 20-4-201 provides The venue may be changed, at any time before trial and T.R.Crim.P. Rule 21 provides for a change of venue if it appears to the court that . . .a fair trial probably could not be had. Waiting until the trial to determine whether a jury can be seated applies a certainty test rather than a prospective probability test. The rule is preventative. It is anticipatory. It is not solely curative as is a post-conviction constitutional attack. Thus, the rule evokes foresight, always a more precious gift than hindsight, and for this reason the same certainty which warrants the reversal of a conviction will not always accompany the change of venue. Succinctly, then it is well-grounded fear that the defendant will not receive a fair and impartial trial which warrants the application of the rule. United States v. Marcello, 280 F. Supp. 510, 513 (E.D. La. 1968), aff'd, 423 F.2d 993 (5th Cir. 1970). Unnecessary expense and undue delay Pretrial determination of venue is also required by T.R.Crim.P. Rule 2 that proscribes that the Rules of Criminal Procedure be construed so as to assure fairness and eliminate unjustified expense and delay result. A construction of Rule 21 to wait until the trial date to determine whether a jury can be seated results unnecessary expense and delay. Both parties are required to prepare for trial and a capital sentencing trial prior to voir dire. The State has agreed to use jury questionnaire. The preparation of that questionnaire depends, in large part, on the location of the venire. If after an attempt in Blount County a jury can not be seated, both parties will incur the additional expense required to re-prepare for the trial in a new venue. Witnesses and jurors are also inconvenienced and put to unnecessary expense by this procedure. If pretrial venue is moved prior to the trial then this unnecessary expense and delay is avoided. On the other hand, if the Court hears the motion pretrial and determines the cause is not sufficient to change venue at that time, the alternative of change of venue always remains if a jury can not be selected at a later time. Other cause to change venue It is critical to a proper application of T.R.Crim.P. Rule 21(a) and T.C.A. 20-4-201 to recognize there are different causes for changing venue, i. e., (1) undue excitement against the defendant; (2) prejudicial publicity; or (3) any other cause. Undue excitement and prejudicial publicity are the most common "causes" or reasons for changing venue. Defendant Sudderth asserts that both undue excitement and prejudicial publicity constitute cause for a change of venue in this case. Waiting until trial to see if a jury can be selected addresses only the issues of undue excitement and prejudicial publicity. In addition to undue excitement and prejudicial publicity, Mr. Sudderth asserts "other cause" for a Rule 21/TCA 20-4-201 change of venue that makes it appear . . . a fair trial probably could not be had in Blount County. The other causes include (1) narrowing the jury venire to exclude African-Americans, (2) creditability of the Blount County Sheriffs Department, (3) creditability of the Blount County District Attorneys office, and (4) the racial composition of the jury venire. These "other causes" will not be resolved by waiting to trial to see if a jury can be selected. 1. Narrowing of the jury venire to exclude African-Americans. An accused is constitutionally entitled to a jury of their peers. Mr. Sudderth is African-American. According the U.S. Census Bureau the projected 1999 Blount County population consists of approximately 2.9% African-Americans. Knox County, the nearest county where cause for change of venue does not exist, has 8.6 % African-American population and the State of Tennessee has 16.4%.  Demographics in Blount County result in most African-Americans living within a small community within Blount County. Stacy Sudderth, A. C. Copeland, Homer Henderson, Bella Brown, Lynn Porter and Andre Jackson all live within this smaller community. The events preceding the death of Andre Jackson, including the rape of Lynn Porter, all occurred within the smaller African-American community within Blount County. Just as members of a neighborhood are more aware of activities occurring in or affecting that neighborhood, members of the smaller Blount County African-American community have move knowledge of matters of concern to their community than members of Blount County as a whole. It is probable that members of the smaller African-American community within Blount County will have knowledge of inadmissible facts, defendants or witnesses that disqualify them from siting in this case. "Probability" is the test for change of venue. Because of the demographics and knowledge within the smaller African-American community within Blount County it is probable that the jury venire will be narrowed to exclude persons because of their race. Because of this, African-Americans will be eliminated from the potential jury venire in Blount County disproportionately in comparison with non-African-Americans. If venue were in a different county African-Americans would not be disproportionately disqualified nor would the jury venire be narrowed to exclude African-Americans. 2. Blount County Sheriffs Department. The conduct of the Blount County Sheriffs Department in its investigation and credibility of its officers will be a material issue in this case. It is probable that many, if not the majority, of the prospective venire in Blount County voted for the current Sheriff. It is also probable that many of the prospective venire know someone in the Sheriffs department. If this case is tried in Blount County, employees of the Blount County Sheriff will have custody of the sequestered jury. If effect, the Blount County Sheriffs Department becomes the host of the jury during their sequestration. Indeed, Detective Manuel of the Blount County Sheriff's Department is the prosecutor on this presentment and will be present before the jury throughout the trial. Detective Manual's co-workers will have custody of the very jury in which Detective Manual's creditability is placed in issue. Employees of the Sheriff's Department had the care of Ashley James during the A. C. Copeland trial similar to the care of the sequestered jury. There are allegations that members of the Sheriffs department in the trial of A. C. Copeland allowed misconduct of Ashley James who was under their care. In this case, the jury will compare their care by the Blount County Sheriff's Department to that of Ashley James in evaluating evidence of misconduct of Ashley James. In addition, Myron Kellog and other potential witnesses have relatives who are employees of the Sheriffs department who have access to persons sequestered by the Sheriffs department. In Blount County, Mr. Sudderth is at a disadvantage by having a jury that has a political interest in the Blount County Sheriffs Department and employees of that office and having a jury whose host during sequestration is the Blount County Sheriff's Department. In a different venue the relationship of jurors and witnesses to the Blount county Sheriffs office would be a non-issue. 3. Blount County District Attorneys Office. The conduct of members of the Blount County District Attorneys office during its investigation, preparation and presentation of witnesses will be a material issue in this case. It is probable that many, if not the majority, of the prospective venire in Blount County voted for the current District Attorney. It is also probable that many of the prospective venire know someone in the District Attorneys office. In Blount County, Mr. Sudderth is at a disadvantage by having a jury venire with a potential bias toward the Blount County District Attorneys office and its employees. In a different venue the relationship of jurors to the Blount District Attorneys office would be a non-issue. 4. Race. In the July 2000 trial of A. C. Copeland there was not a single African-American on the jury. As noted above, African-Americans comprise only 2.9% of the Blount County population while African-Americans comprise of 16.4% of Tennessee's population. Knox County has 8.6% African-American population. The defense does not assert that a defendant is entitled to a racial quota on a jury venire. This Court will instruct the jury selected in Mr. Sudderths case to use its common sense in evaluating the evidence. Mr. Sudderth stated at the time of the death of Andre Jackson, and continues to assert, that he offered a $10,000 reward for information as to who raped the mother of his children. Mr. Sudderth did not trust Blount County law enforcement to resolve crimes among African-Americans, among his family or his friends. Common sense of a minority as to trusting law enforcement is different from common sense of a member of the majority. It takes both views on a jury to have a meaningful understanding of the various views of common sense. Nor does the defense assert that a change of venue is required solely because of the low number of minorities in a county. What the defense asserts is that racial composition of a county is a factor to consider along with other factors in changing venue. Publicity Attached under Attachment 3 are copies of newspaper accounts of the trial of A. C. Copeland, Stacy Sudderth and related subjects. The following is a summary of those articles: THE DAILY TIMES 1. Slaying-rape link suspected (4/8/98) 2. Man named in murder warrant (4/9/98) 3. Man held in shooting says he was kidnapped; $10,400, gun found in vehicle (4/10/98) 4. Arson may be tied to rape, homicide (4/16/98) 5. Shooting victim now jailed (4/22/98) 6. Security tight at murder hearing (6/2/98) 7. Alcoa man bound over to grand jury in shooting (10/29/98) 8. Accused killer sues men who allegedly shot him (4/16/99) 9. Man stabbed in throat in Alcoa; suspect in custody (5/19/99) 10. 2 face federal drug charges (6/4/99) 11. Alcoa man violates sentencing terms, faces prison (6/29/99) 12. Teens rape trial case of terror prosecutor says (10/24/99) 13. State rests in rape trial (10/25/99) 14. Man get 31 years for rape, theft (12/21/99) 15. Man sought in 98 murder (7/1/00) 16. Search for Sudderth fans out across area (7/2/00) 17. Man sought on murder charges surrenders (7/3/00) 18. Testimony points to conspiracy (7/19/00) 19. Witness in Copeland trial tells of conspiracy (7/20/00) 20. State rests in Copeland trial (7/21/00) 21. Copelands defense rests in murder trial (7/22/00) 22. Copeland found guilty (7/23/00) 23. Death penalty for Copeland (7/25/00) 24. Feds put hold on Sudderth release (10/21/00) 25. Judge denies Sudderth indigency claim (11/1/00) 26. Judge recuses himself for trial (3/29/01) 27. Because they could not find witnesses, now theyre whining because they didnt get what they wanted out of our witnesses, Andrews said. - Assistant District Attorney Kirk Andrews - Lawyers argue for new trial for murder convict - Copelands defense claims photos, time limits, instructions to jury unfair (5/30/01) 28. Copeland gets another day in court (6/2/01) 28. Convicted murderer requests new counsel, new trial, jewelry (6/15/01) Counsel is informed that The Daily Times recently sent a mailing to all addresses in Blount County advertising its paper. That advertisement included a copy of the front page of the edition of The Daily Times that read "Copeland found guilty". Without question Blount County has been saturated with publicity regarding the death of Andre Jackson and related prosecutions. Most, if not all of the publicity is regarding facts that are not admissible in Mr. Sudderth's case and constitute Rule 24(c) excusals for cause. Sentinel. Regarding publicity, the applicable test is whether "there is a reasonable likelihood that prejudicial news prior to trial will prevent a fair trial." Sheppard v. Maxwell, 384 U.S. at 363 (1966). Indeed, as Justice Black said "our system of law has always endeavored to prevent even the probability of unfairness." In re Murchinson, 349 U.S. 133, 136, 75 S.Ct. 623, 625, 99 L.Ed. 942 (1955). The Tennessee Court of Criminal Appeals set forth a non-exclusive list of factors to be considered in determining whether to grant a change of venue based on undue excitement or prejudicial publicity. State v Hoover, 594 S.W.2d 743, 746 (Tenn.Crim.App. 1979). These seventeen (17) factors, known as the Hoover factors, have been adopted by the Tennessee Supreme Court. See State v. Bates, 804 S.W.2d 868, 877 (1991); State v. Melson, 638 S.W.2d 342, 361 (1982). They are (1) Nature, extent, and timing of pre-trial publicity; (2) Nature of publicity as fair or inflammatory; (3) The particular content of the publicity; (4) The degree to which the publicity complained of has permeated the area from which the venire is drawn; (5) The degree to which the publicity circulated outside the area from which the venire is drawn; (6) The time elapsed from the release of publicity until the trial; (7) The degree of care exercised in the selection of the jury; (8) The ease or difficulty in selecting the jury; (9) The veniremen's familiarity with the publicity and its effect, if any, upon them as shown through their answers on voir dire; (10) The defendant's utilization of his preemptory challenges; (11) The defendant's utilization of challenges for cause; (12) The participation by police or by prosecution in the release of publicity; (12) The severity of the offense charged; (14) The absence or presence of threats, demonstrations or other hostility against the defendant; (15) Size of the area from which the venire is drawn; (16) Affidavits, hearsay or opinion testimony of witnesses; (17) Nature of the verdict returned by the trial jury. State v Hoover, 594 S.W.2d 743, 746 (Tenn.Crim.App. 1979). In the cases where the court considered the jurors indifferent although they had previously heard about the defendant, it was one factor, such as publicity of a prior conviction or a recent trial or suspicion of another crime, that the defendant put forth as reason to overturn the denial of venue. State v. Bobo, 727 S.W.2d 945 (Tenn. 1987), State v. Howell, 868 S.W.2d. 238 (Tenn. 1993), State v. Hartman, 703 S.W.2d 106 (Tenn. 1985). In most cases, the publicity concerned the charges against the defendant that would be addressed in the trial the jury were sitting for. See State v. Harris, 839 S.W.2d 54 (Tenn. 1992), State v. Evans, 838 S.W.2d 185 (Tenn. 1992), State v. Bates, 804 S.W.2d 868 (Tenn. 1991). Mr. Sudderths case is front-page news in Blount County. Last year, A. C. Copelands case was front-page. Allegations of Mr. Sudderth being a co-conspirator with Mr. Copeland was a prominent part of the publicity during A. C. Copelands trial. A. C. Copelands post-trial motions are ongoing. The Blount County venire is well informed that A. C. Copeland was sentenced to death. The guilty verdict in A. C. Copelands trial is admissible in Mr. Sudderths trial. The death sentence for A. C. Copeland is admissible in Mr. Sudderths trial. Challenges for cause are applicable to prospective jurors who have knowledge of these inadmissible matters pursuant to T.R.Crim.P. Rule 24 (b)(2). If this case is tried in Blount County these well-known disqualifying facts must be explored on voir dire. If this case is tried in Knox County little, if any, voir dire will be required to address these disqualifying facts. It is difficult, if not impossible, to determine which jurors have knowledge of these inadmissible facts without informing the jurors of the facts. Another problem is that jurors may not recall these facts during voir dire, but during the case, when confronted with more specific information, jurors may recall disqualifying facts during the trial. Just one juror with knowledge of these disqualifying facts taints the entire jury. In Knox County, there has been no publicity of the trial or conviction of A. C. Copeland or the death sentence and these inadmissible facts are a non-issue. Contravailing interest Prosecutors often argue that the State is entitled to a trial in the venue where the crime was committed. In fact, venue is established by law to be in the County of the commission of the offense. There is no right, however, of the State to a particular venue when there are reasons to believe the defendant can not receive a fair trial in that venue. T.R.Crim.P. Rule 21, T.C.A. 24-4-101 and our constitutions look to whether the Defendant, not the State, probably can not receive a fair trial in a venue. Prosecutors often argue that convenience to witnesses, the court, counsel or jurors are factors to consider in changing venue. While the authority for considering these factors is questionable, in this case, even if these factors are considered, these factors favor Knox County as the venue of this trial over Blount County. The Blount County Justice Center is approximately a 15 minute drive from the Knox County City-County Building. Because there is a designated judge in this case from out-of-town, convenience to the judge is a non-factor or favors Knoxville because there are more lodging and food accommodations in Knoxville within walking distance of the court. If the Blount County prosecutors are disqualified, prosecutors pro tem have more accommodations available to them in Knox County than in Blount County. The Knox County District Attorneys office is available for use by any prosecutor pro tem or the Blount County prosecuting attorneys if they are not disqualified. Mr. Sudderth is represented by counsel from Knox County who have their offices, research and staff readily available for use during a trial in Knox County. Witnesses can drive to the Knox County court just as easily as the Blount County court. There are more alternatives for the lodging and care of a sequestered jury in Knox County than in Blount County. All logistical factors favor Knox County over Blount County. Conclusion Selection of the venue in this case should be determined as soon as possible prior to trial. Waiting to see if a jury can be selected in Blount County will not resolve reasons that venue should be changed and will result in unnecessary expense and undue delay. Simply stated, there are no reasons not to change venue and there are numerous reasons why venue should be changed to assure Defendant Sudderth a fair trial. Knox County is the nearest venue in which the reasons for changing venue do not exist. Pursuant to T.R.Crim.P. Rule 21(d) venue should be immediately changed to Knox County whereby arrangements can begin in Knox County for the trial of this case. This ____ day of July 2001. ___________________________ HERBERT S. MONCIER Attorney for Defendant Herbert S. Moncier Suite 775, Bank of America Center. 550 Main Avenue Knoxville, Tennessee 37902 (865)546-7746 BPR #1910 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served upon the office of the District Attorney General for Blount County, Tennessee, this the ____ day of July, 2001. ___________________________ HERBERT S. MONCIER  At the hearing on June 20, 2001 the Court discussed its practice of waiting until jurors are called in Blount County to determine the degree of difficulty in seating a jury in Blount County.  Affidavit of Herbert S. Moncier  Attachment 1.  Ibid. footnote 2.  There are a number of other potential witnesses who live in the smaller African-American community within Blount County who are not listed on the presentment. On June 20, 2001 this Court ordered the prosecutors to notify in writing any witness they intend to call at trial within 48 hours of learning of that witness. The State has not listed any witnesses other than those on the presentment and has not provided 48 hour notice of additional witnesses as ordered. The defense objects to the State adding any new witnesses.  Ibid. footnote 2.  This cause actually is related to cause resulting from undue publicity. The affect of the publicity is enhanced because the publicity relates to the smaller Blount County African-American community and its residents. Because the affected community consist of African-Americans constitutional prejudice results from the disproportionate and thereby discriminatory elimination of jurors because of their race.  Ibid. footnote 2, Attachment 2.  Ibid. footnote 2, Attachment 2.  Defendant adopts the materials submitted in support of Defense Motion 109: Motion to Disqualify Prosecutors in support of this cause to change of venue.  Ibid footnote 2, Attachment 1.  Counsel is attempting to locate a copy of that advertisement and will present it to the Court if located. Otherwise an affidavit will be provided.  Ibid. footnote 2, Attachment 3 PAGE 1 PAGE 15 3jk      V Gmop:<EXYf8;=@CVRkg!!*#+#,#-###+$,$$$%%)+)..hOJQJh5OJQJh5B*phhCJOJQJh5CJOJQJhB*ph h>*jh0JUh h5E234LU^g}mG   $da$$da$$1$a$$1$a$$a$$a$L`fff   op;rQRG<e! 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