State v. Keen
David M. Keen pled guilty to first-degree murder and aggravated rape of an 8-year-old girl. A jury sentenced him to death, finding multiple aggravating circumstances, including the victim's age, heinousness, and the murder occurring during rape. Keen appealed, raising 17 issues, primarily concerning jury instructions on mitigating circumstances and the death penalty statute. The Supreme Court of Tennessee found errors in the jury instructions regarding the weighing of aggravating and mitigating circumstances and the definition of 'heinous, atrocious, or cruel' aggravating circumstance. Consequently, the Court affirmed the conviction but remanded the case for a new sentencing hearing.