State of Tennessee v. Tammy Hart
Defendant Tammy Hart was indicted and convicted in Johnson County Criminal Court for child endangerment, vehicular homicide, and aggravated vehicular homicide following a head-on collision that resulted in a fatality. The trial court merged the vehicular homicide conviction into the aggravated vehicular homicide conviction and sentenced Hart to consecutive terms. On direct appeal to the Court of Criminal Appeals of Tennessee at Knoxville, Hart raised four issues: the denial of her motion to suppress medical records, the admission of those records into evidence, a violation of her constitutional right to confrontation, and the insufficiency of evidence to sustain her convictions. The appellate court affirmed the trial court's judgments, concluding that the State did not violate Hart's Fourth Amendment rights in subpoenaing her medical records, the records were admissible as business records, her confrontation rights were not violated due to waiver and ample cross-examination opportunities, and sufficient evidence supported the aggravated vehicular homicide and child endangerment convictions, citing her intoxication and prior DUI history.