Facts
Rogers stabbed James Bowdery with a butcher knife on May 6, 1994. One of the stab wounds penetrated Bowdery's heart, and during surgery to repair the wound, Bowdery went into cardiac arrest. Bowdery survived, but due to cerebral hypoxia Bowdery slipped into a coma. Eventually Bowdery developed a kidney infection, from which he died on August 7, 1995, 15 months after the stabbing. The medical examiner ruled the cause of death as cerebral hypoxia "secondary to a stab wound to the heart."
Rogers was convicted of second-degree murder under Tennessee's homicide statute, which does not include the year and a day rule. Rogers appealed to the Tennessee Court of Criminal Appeals, arguing that the year-and-a-day rule was part of the common law of Tennessee, despite its absence from the Tennessee homicide statute. The appellate court disagreed, noting that the state's Criminal Sentencing Reform Act had abolished all common-law defenses in criminal cases, including the year-and-a-day rule.
Rogers appealed again to the Tennessee Supreme Court. The court held that the common-law year-and-a-day rule survived in Tennessee, but was outmoded. It therefore abolished the rule. Rogers had also argued that abolishing the rule after he had committed his crime would violate the Ex Post Facto Clause of Article I of the U.S. Constitution. The Tennessee Supreme Court disagreed, reasoning that although judicial decisions can be ex post facto laws, retroactive abolition in this case would not offend due process principles because the year-and-a-day rule was so outmoded that a reasonable person would not expect it to exist under modern law. The U.S. Supreme Court agreed to hear the case at Rogers's request.
Read more about this topic: Rogers V. Tennessee
Famous quotes containing the word facts:
“Still, it will sometimes strike a scientific man that the philosophers have been less intent on finding out what the facts are, than on inquiring what belief is most in harmony with their system.”
—Charles Sanders Peirce (1839–1914)
“Now, what I want is, Facts. Teach these boys and girls nothing but Facts. Facts alone are wanted in life. Plant nothing else, and root out everything else. You can only form the minds of reasoning animals upon Facts: nothing else will ever be of any service to them. This is the principle on which I bring up my own children, and this is the principle on which I bring up these children. Stick to Facts, sir!”
—Charles Dickens (1812–1870)
“Had Adam tenderly reproved his wife, and endeavored to lead her to repentance instead of sharing in her guilt, I should be much more ready to accord to man that superiority which he claims; but as the facts stand disclosed by the sacred historian, it appears to me that to say the least, there was as much weakness exhibited by Adam as by Eve. They both fell from innocence, and consequently from happiness, but not from equality.”
—Sarah M. Grimke (1792–1873)