HEATH BELL v. STATE OF TENNESSEE - Articles

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HEATH BELL v. STATE OF TENNESSEE

Posted by: Azya Thornton on Apr 2, 2026

Court: TN Court of Criminal Appeals

Attorneys 1: Josie S. Holland, Memphis, Tennessee, for the appellant, Heath Bell.

Attorneys 2: Jonathan Skrmetti, Attorney General and Reporter; G. Kirby May, Assistant Attorney General; Steven J. Mulroy, District Attorney General; and Leslie Byrd, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge(s): MCMULLEN

The Petitioner appeals from the order of the post-conviction court denying his petition seeking relief from his conviction for first-degree murder. In this appeal, the Petitioner argues (1) that trial and appellate counsel provided ineffective assistance of counsel in failing to object to or raise as an issue on appeal the admissibility Chamere Talley’s prior statement based on Tennessee Rule 803(26); (2) that the State and the trial court violated due process in failing to conduct a hearing pursuant to Rule 803(26); (3) that trial counsel was ineffective in failing to conduct an adequate closing argument; and (4) that the cumulative effect of trial counsel’s errors deprived the Petitioner of a fair trial.1 We affirm.

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