Friday, November 15, 2013

Rogers v. Tennessee case brief

Rogers v. Tennessee case brief summary
532 U.S. 451 (2001)

Petitioner was convicted of murder, and alleged that his conviction was precluded under common law since the victim did not die within a year and a day after petitioner's act. Upon petition for writ of certiorari, petitioner appealed the judgment of the Supreme Court of Tennessee, which judicially abolished the year and a day rule in the state and upheld petitioner's conviction.

Prior to his death, the victim remained comatose for approximately 15 months after being stabbed by petitioner, and the medical examiner determined that the victim's death was caused by petitioner's act. Petitioner argued that the common law year and a day rule precluded his murder conviction, but the highest state court abolished the rule and held that the retroactive application of such abolition did not violate the Due Process Clause.


  • The United States Supreme Court held that, while petitioner was entitled to fair warning of conduct deemed criminal, the abolition of the year and a day rule after petitioner stabbed the victim did not violate due process since elimination of the rule was not unexpected and indefensible by reference to the law which had been expressed prior to the stabbing. 
  • The rule was outdated and archaic, abolished in numerous other jurisdictions, and was never relied upon as a ground of decision. 
  • Abolishing the rule thus constituted the routine exercise of common law decision making, rather than a marked and unpredictable departure from prior precedent, which brought the law into conformity with reason and common sense.

Judgment upholding petitioner's conviction was affirmed.

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