Dennis Pylant v. State of Tennessee

Summary

The Tennessee Supreme Court held that the post-conviction court abused its discretion in striking as hearsay the testimony of witnesses who recounted Amanda Davis' incriminating statements, because at the post-conviction hearing those statements were offered to show that trial counsel knew of potentially exculpatory evidence, not for the truth of the matter asserted. The Court further concluded that trial counsel performed deficiently by delegating the decision whether to call Davis to a 'vote by committee,' thereby foreclosing material and admissible exculpatory proof. Because the post-conviction court made no credibility findings about the proffered witnesses, the Court could not evaluate prejudice and reversed the Court of Criminal Appeals, remanding for a new post-conviction hearing.