State of Tennessee v. Jerome Antonio McElrath - Concurring In the suppression of evidence dissenting from the adoption of an exclusionary rule exception for constitutional violations caused by careless police recordkeeping

Tenn.March 12, 2019No. W2015-01794-SC-R11-CD

Plaintiff WinUnion City Police Department

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Case Details

Judge(s): Justice Sharon G. Lee
Status — whether other courts must follow this ruling: Published
Procedural Posture — the stage the case had reached: trial verdict

Related Laws

No specific laws identified for this ruling.

Outcome

The court upheld the suppression of evidence due to systemic errors in police recordkeeping, agreeing that McElrath's constitutional rights were violated.

Excerpt

A Union City Police Department officer twice arrested and searched Jerome Antonio McElrath because of systemic and long-standing errors in the police department's records. By stopping and searching McElrath without probable cause based on these errors, the police violated McElrath's constitutional right to be free from unreasonable searches and seizures. I disagree with the majority's adoption of an exception to the exclusionary rule to excuse negligent police recordkeeping. That said, I agree with the majority's conclusion that the negligence exception does not apply here because of the police department's systemically flawed recordkeeping process. The majority provides a good roadmap for trial courts to make the fact-intensive determination of whether isolated or systemic negligence caused the police error thus, whether the negligence exception applies.

What This Ruling Means

**What Happened** Jerome McElrath was arrested and searched twice by Union City Police Department officers based on incorrect information in their computer system. The police records contained errors that made it appear McElrath had outstanding warrants or other issues when he actually didn't. These weren't one-time mistakes – the police department had ongoing, widespread problems with keeping accurate records. When officers relied on these flawed records to stop and search McElrath, they violated his constitutional rights against unreasonable searches. **What the Court Decided** The court ruled that evidence obtained from these unconstitutional searches should be thrown out. Even though the individual officers may not have intentionally violated McElrath's rights, the court found that the police department's systemic record-keeping problems were serious enough that they couldn't excuse the violations. The court rejected applying an exception that might have allowed the evidence to be used despite the constitutional violation. **Why This Matters for Workers** This ruling protects all workers from being unfairly targeted due to employer negligence with records. It establishes that organizations – including government employers – cannot escape accountability for constitutional violations simply because their poor record-keeping was careless rather than intentional. This precedent helps ensure workers have recourse when institutional failures harm their rights.

This summary was generated to explain the ruling in plain English and is not legal advice.

N.J.Jun 2019

Remanded

Derinda Carr v. Windham Professionals, Inc.

Tenn.Apr 2022

Appellant Derinda Carr challenges the trial court's finding her neck injury did not arise primarily "out of and in the course and scope of' her employment. The appeal has been referred to the Special Workers' Compensation Appeals Panel for a hearing and a report of findings of fact and conclusions of law pursuant to Tennessee Supreme Court Rule 51. We agree with the trial court and affirm the judgment.

Defendant Win

Bethany Shelton v. Hobbs Enterprises, LLC

Tenn.Sep 2021

Bethany Shelton ("Employee") filed a petition for benefit determination against Hobbs Enterprises, LLC ("Employer") alleging an injury to her right shoulder suffered in a work- related accident on August 26, 2017. She sought temporary total, permanent partial, and continued medical benefits. Following the issuance of a dispute certification notice, Employer moved for summary judgment on the basis the only medical testimony, from the Employee's treating orthopedic surgeon, Dr. Sean Kaminsky, was insufficient as a matter of law to establish causation. The Court of Workers' Compensation Claims (the "trial court") denied the motion and denied Employer's motion to reconsider. Employer sought an expedited appeal before the Workers' Compensation Appeals Board, but then sought and was granted a dismissal of that appeal. A trial was held, after which the trial court denied Employee's claim on the ground she had failed to meet her burden to establish her right shoulder injury arose primarily out of and in the course and scope of her employment with Employer. Employee filed a motion to reconsider, which the trial court denied. She appealed directly to the Supreme Court. The appeal has been referred to the Special Workers' Compensation Appeals Panel for a hearing and a report of findings of fact and conclusions of law pursuant to Tennessee Supreme Court Rule 51. We affirm the judgment of the Court of Workers' Compensation Claims.

Defendant Win

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This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

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