State v. Payne

The defendant was convicted in 1988 by a Shelby County jury of two counts of first-degree murder and one count of assault with intent to commit first-degree murder. He was sentenced to death for the murder convictions and 30 years of imprisonment for the assault conviction. In 2021, the Tennessee legislature enacted a statute allowing death-sentenced inmates to seek an intellectual disability determination. The defendant filed a petition under this statute in 2022, and lower courts vacated his death sentence and imposed two life sentences to run consecutively. The court held that Section 39–13–203(g) granted the trial court jurisdiction to only determine the defendant’s intellectual disability and vacate his death sentences, but it did not authorize revisiting the alignment of his sentences.