## Facts

- Larry Coulter fatally shot his estranged wife and was charged with first-degree premeditated murder.
- Coulter did not deny firing the shot but claimed the shooting was impulsive, not premeditated, and that he did not consciously pull the trigger.
- The State presented a firearms identification expert who testified the revolver required substantial trigger pressure in double-action mode (about 12 pounds) to fire without cocking the hammer.
- After the expert’s testimony, the State asked that each juror be permitted to “dry-fire” (pull the trigger on) the unloaded murder weapon in the courtroom to experience the force required.
- Coulter objected, arguing jurors could handle the exhibit during deliberations; the trial court overruled the objection and allowed the in-court dry-firing under the court’s supervision.
- The jury convicted Coulter of first-degree premeditated murder, and the trial court imposed a life sentence.

## Issues

1. Whether the trial court erred by allowing each juror, during the State’s case-in-chief, to dry-fire the unloaded murder weapon in open court.
2. Whether the trial court committed reversible error regarding multiple additional claims, including prosecutorial-disqualification requests, suppression motions, evidentiary rulings, procedural rulings, jury instructions, sufficiency of the evidence, and cumulative error.

## Decision

- The Tennessee Court of Criminal Appeals affirmed the conviction and life sentence.
- The court held the trial court acted within its discretion in permitting jurors to dry-fire the unloaded weapon in open court after expert testimony.
- The court rejected Coulter’s remaining claims, including challenges to suppression rulings, evidentiary and procedural decisions, jury-instruction rulings, and the sufficiency of the evidence of premeditation.
- The court found no cumulative error warranting a new trial.

## Legal Principles

- Trial courts have broad discretion to control how jurors may examine admitted physical exhibits.
- A supervised, in-court demonstration involving an admitted exhibit, tied to testimony already in evidence, may be treated as permissible juror examination rather than an improper juror experiment.
- A demonstration is less likely to be reversible error where it occurs in open court under judicial supervision and does not introduce extraneous information outside the evidentiary record.
- Appellate review of such exhibit-handling decisions is for abuse of discretion; reversal requires a showing of prejudicial error.
- In assessing sufficiency of the evidence for premeditated murder, the jury may reject a defendant’s claim of impulsivity based on the totality of proof, including forensic evidence and circumstances before and after the killing.

## Conclusion

The court affirmed Coulter’s first-degree premeditated murder conviction, holding that allowing jurors to dry-fire the unloaded, admitted weapon in open court after expert testimony was a permissible, supervised examination of an exhibit within the trial court’s discretion and did not create reversible error.


State v. Coulter, 67 S.W.3d 3 (Tenn. Crim. App. 2001)