TBA Law Blog


Posted by: Azya Thornton on Jun 16, 2025

The Tennessee Supreme Court issued a decision in State of Tennessee v. Pervis Tyrone Payne affirming the trial court’s modification of Payne’s death sentences but vacating its order that the sentences be served concurrently instead of consecutively. Payne was convicted of two counts of first-degree murder in 1987 for the murders of Charisse Christopher and her 2-year-old daughter, and the attempted murder of Christopher’s 3-year-old son. The court ruled that while a 2021 law allowed the trial court to reduce Payne’s death sentences due to intellectual disability, it did not authorize the court to change the sentencing alignment. As a result, Payne’s life sentences must be served consecutively, delaying his eligibility for parole. Shelby County Criminal Court Judge Paula Skahan had ruled in February 2022 that Payne would serve his two life sentences concurrently, which would have made him eligible for parole in five years. His death penalty sentence was officially vacated in November 2021.