A Tennessee court has overturned the conviction of a man who killed a Black transgender woman, ruling that a lower court “erred” by preventing the killer from using the victim’s trans identity in his defense.
Samuel Ward Jr. shot Paris Lee six times outside her Memphis home in June 2022, according to the Shelby County District Attorney’s Office. He then drove 30 minutes home, leaving her to die. Ward was convicted of voluntary manslaughter in May 2025.
But the Tennessee Court of Criminal Appeals in Jackson overturned that conviction on Monday and ordered a retrial. The trial court’s judge had disallowed the defense from presenting the victim’s identity as a transgender woman in its arguments.
“The trial court erred by excluding evidence of the victim’s assigned sex at birth, [and] the evidence was insufficient to support [Ward’s] conviction,” reads the Monday appellate court decision. “Because we conclude that the trial court erred… we reverse and remand this case for a new trial.”
The defense had argued it would be more reasonable for Ward to fear Lee if jurors knew she was assigned male at birth, and said jurors would be more prejudiced against Ward for killing a cisgender woman, according to Jamie Satterfield, an independent journalist who first reported the ruling.
The gay panic defenses has not gone away. Also, this rings of saying its not murder because transgender people aren’t people.
I completely agree with you. It’s difficult because defendant with indicted for manslaughter, so the DA would need to request a new grand jury to try to get the charge added. It seems like TCA § 39-13-202 (first) could possibly apply due to a gun being brought and TCA § 39-13-210 (second) could easily apply since it only requires knowledge, not intent to kill. What’s strange about this situation to me is I don’t feel like the appeals court was being transphobic, but it feels like not having the trial include TCA § 39-13-210 (second) is very questionable if he was asked to leave and may either involve transphobia from the DA or the grand jury (and it’s possible the grand jury was given the option for TCA § 39-13-210 and rejected it). I stand by the view that it was procedurally wrong to not allow a defendant to testify about their relationship, including that he liked trans women, his subjective views and concerns, and let a jury decide based on that. I am also not entirely sure if a new indictment can be done and then merged with a remanded case that was remanded for a new trial. I don’t think Green v. United States, 355 U.S. 184 (1957) would apply since he was never charged with murder, this is a fairly difficult technical procedural question. It looks like they possibly can? (State of Tennessee v. Brandon Robert Vandenburg (Tenn. Crim. App. 2019), https://law.justia.com/cases/tennessee/court-of-criminal-appeals/2019/m2017-01882-cca-r3-cd.html) It may not matter because the DA is unlikely to consider it. I hope they do add charges. If she was telling him to leave, that’s really a low amount of time. I’m not that familiar with Tennessee law.