Supreme Court of Tennessee Finds Confession by 17 Year-Old Who Was Held Incommunicado For About 7 Hous in the Middle of the Night Was Involuntary
It’s really rare that a court reverses a murder conviction based upon finding a confession to be involuntary. That makes the recent opinion of the Supreme Court of Tennessee in State v. Adkisson, 2026 WL 1542890 (Tenn. 2026), the exception rather than the rule. So, what were the key facts?
Seventeen-year-old Antonio Demetrius Adkisson was charged with two counts of first-degree murder for the fatal shooting of two victims. Despite Adkisson being seventeen and ineligible for capital punishment, the police investigator interrogating him told him that they were “looking at possibly the death penalty.”
The Supreme Court of Tennessee found that this false statement did not render Adkisson’s confession per se involuntary and inadmissible. But, in the end, the court concluded as follows:
In summary, with respect to the totality of the circumstances in this case, the Defendant was roughly eight months shy of turning eighteen, a senior in high school, and appeared intelligent. However, he had no prior experience with the criminal justice system, was held incommunicado for approximately seven hours in the middle of the night, and steadily denied any involvement in the shooting for roughly six hours. He was also repeatedly denied access to his mother during the detention despite his repeated pleas to speak to her, her presence at the station, and police assurances that she could be present. As the detention progressed, the Defendant showed signs of sleep deprivation and emotional distress, at one point repeatedly hitting his head on the table in front of him. He further endured an investigator falsely telling him that police had video evidence concretely proving his guilt and that he could face the death penalty if he did not cooperate and was later told by the Chief of Police that a jury would not believe him innocent even if he did not commit the crime and implied that he would inevitably be sent to adult prison where he would face violence and rape at the hands of adult prisoners.
Accordingly, based on the review of the relevant Climer factors and the totality of the circumstances surrounding the Defendant’s interrogation, we conclude that the Defendant’s statements were involuntary. Therefore, we hold that the trial court erred in denying the Defendant’s motion to suppress and admitting the Defendant’s statements at trial. The Defendant’s convictions of second-degree murder are vacated, and this case is remanded to the trial court for further proceedings consistent with this opinion. Specifically, if the State decides to retry the Defendant, the Defendant’s confession shall not be admissible at trial.