State of Tennessee v. Tyrome Cameron Ferguson

Syllabus

The Defendant, Tyrome Cameron Ferguson, was charged by a Monroe County grand jurywith two counts of aggravated assault and one count of reckless endangerment with adeadly weapon relating to an alleged road-rage incident. On the first day of the Defendant'strial, the trial court found that the State had violated Tennessee Rule of Criminal Procedure16 and declared a mistrial. In a subsequent hearing, the trial court ordered the State to paydefense counsel $500 \as a contribution toward his attorney['s] fees\ as a sanction for itsdiscovery violation. The Defendant's charges were ultimately dismissed by agreement.The State thereafter filed both an application for extraordinary appeal pursuant toTennessee Rule of Appellate Procedure 10 and a petition for common law writ of certiorarichallenging the trial court's assessment of $500. We denied the State's application for anextraordinary appeal but granted its petition for writ of certiorari. State v. Ferguson, No.E2025-00044-CCA-WR-CO (Tenn. Crim. App. Apr. 1, 2025) (Order). Finding that thetrial court's order violated the State of Tennessee's sovereign immunity from suit, we grantcertiorari and reverse and vacate the trial court's order.