TN: The 4A certified question doesn’t resolve the appeal, so appeal dismissed

The certified question related to consent to search was not dispositive to the outcome of the case for purposes of Tenn. R. Crim. P. 37(b)(2)(A). Even if defendant’s consent to search the home was constitutionally invalid and exigent circumstances did not exist, the evidence would have been inevitably discovered. Officers had probable cause to believe that an individual was inside defendant’s home, and the deputies could have obtained and executed a search warrant without defendant’s consent in order to search the home for the individual. Thus, the drug-related evidence would have been inevitably discovered. Since the certified question was not dispositive, the appeal was dismissed. State v. Scott, 2020 Tenn. Crim. App. LEXIS 19 (Jan. 16, 2020).*

Decedent had a knife at his throat and officers fired beanbag rounds at him to get him to drop the knife. Instead he charged them. The use of deadly force was subject to qualified immunity. Estate of Gaona v. City of Santa Maria, 2020 U.S. App. LEXIS 1453 (9th Cir. Jan. 14, 2020).*