Jessie Dotson v. State of Tennessee

Syllabus

This appeal involves a capital post-conviction petitioner's expert funding requests under Tennessee Supreme Court Rule 13. A jury convicted the Petitioner, Jessie Dotson, of six counts of premeditated first-degree murder and sentenced him to death. This Court affirmed the jury's verdict. The Petitioner filed for post-conviction relief, alleging several grounds of ineffective assistance of counsel. He requested funds under Tennessee Supreme Court Rule 13 to hire expert witnesses to assist in establishing his claims of ineffective assistance of counsel. The post-conviction court authorized the funds, but the Director of the Administrative Office of the Courts (AOC) and the Chief Justice denied approval for some of the Petitioner's requested experts. After an evidentiary hearing, the post-conviction court denied relief. The Court of Criminal Appeals affirmed the ruling without deciding the Petitioner's Rule 13 constitutional challenges. We granted review to consider the Petitioner's constitutional issues regarding Rule 13. We hold the provisions of Rule 13 are constitutional as applied the Petitioner was not unconstitutionally denied appellate review of the denial of his request for expert funds and the Petitioner was not deprived of a full and fair post-conviction hearing due to the denial of expert funds.