Tennessee Court Vacates Conviction in Trans Woman’s Killing

The court ruled that excluding Paris Lee's transgender identity undermined Samuel Ward Jr.'s self-defense claim.

By John Riley on October 13, 2026 @JRileyMW

Samuel Ward Jr. - Photo: Shelby County Sheriff's Office, Paris Lee - Photo: Facebook — Samuel Ward Jr. – Photo: Shelby County Sheriff’s Office, Paris Lee – Photo: Facebook

The Tennessee Court of Criminal Appeals has overturned the voluntary manslaughter conviction of a man who killed a Black transgender woman, ruling that a lower court “erred” by preventing him from using the victim’s transgender identity in his self-defense claim.

Samuel Ward Jr. fatally shot Paris Lee at her home in Cordova, Tennessee, on June 29, 2022. A Shelby County jury found him guilty of voluntary manslaughter in May 2025.

In testimony presented at trial, Ward’s account was that he had gone to Lee’s home and gotten into a verbal altercation with her, during which she asked him to leave. According to the Shelby County District Attorney’s Office, he claimed Lee pointed a gun at him while they were at the top of a staircase, causing him to fall backward. He told police that he drew his own weapon and fired upward from the bottom of the stairs, striking Lee.

But as the district attorney’s office noted in a statement, physical evidence and expert testimony from a medical examiner contradicted Ward’s version of events. Lee was shot six times, and the trajectories of those wounds did not align with Ward’s statement. Ward also had no visible injuries following the confrontation.

Tarik Hunter, Lee’s best friend, testified that he had been on the phone with Lee just prior to the shooting and heard Ward yelling in the background and Lee repeatedly asking him to leave.

Prosecutors also said Ward left the scene and drove 30 minutes to his home before calling 911 — actions that did not appear to align with his claims of self-defense.

However, as reported by Jamie Satterfield for her Substack The Smoky Files, the Tennessee Court of Criminal Appeals — in the first ruling of its kind in Tennessee’s legal history — overturned Ward’s conviction and ordered a retrial on October 5.

Prior to trial, Ward’s legal team had argued that jurors would consider his fear of Lee more reasonable if they knew she had been assigned male at birth, and that allowing them to assume Lee was a cisgender woman could prejudice them against him and his claims of self-defense.

Prosecutors had objected, arguing that Lee’s size and strength, or her assigned sex at birth, were irrelevant because Ward never alleged she physically threatened or assaulted him, and Lee was armed with a firearm, negating any alleged physical advantage she may have possessed. They also argued that Lee’s transgender status would likely prejudice jurors against her and in favor of Ward.

Shelby County Criminal Court Judge Carlyn Addison ultimately sided with the prosecution, excluding references to Lee’s assigned sex at birth from evidence presented to the jury, including the autopsy report, autopsy photographs, and crime scene photographs and footage.

The Court of Criminal Appeals found that Lee’s transgender identity was not only relevant but essential to Ward’s claims of self-defense. The appellate court ruled that, by excluding evidence of Lee’s assigned sex at birth, Addison “abused [her] discretion by causing an injustice to Defendant.”

“By excluding the evidence, the trial court denied Defendant an opportunity to present his defense. Such error was not harmless,” Judge Timothy L. Easter wrote on behalf of the three-judge panel. “Withholding the fact of the victim’s biological sex frustrated a verdict dictated on truth and justice by asking the jury to render justice without absolute truth.”

The court rejected the idea that Ward’s possession of a gun would have negated any physical advantage Lee may have had.

“While a gun might equalize differences in physical strength and size, there are other inherent physiological differences between the sexes that science continues to reveal and that we choose not to ignore,” Easter wrote. “We decline to hold that the biological sex of the victim is not relevant to a claim of self-defense.”

The appellate court also rejected Addison’s concern that knowledge of Lee’s transgender identity would unfairly prejudice jurors against the prosecution’s case.

“Regarding the danger of unfair prejudice, we recognize that societal biases exist. As counsel for Defendant observed at the pretrial hearing, any prejudices the jury might have against the victim for being transgender could very well be applied to Defendant for being in a sexual relationship with the transgender victim,” Easter wrote.

It remains unclear whether the Tennessee Attorney General’s Office will seek review of the ruling by the Tennessee Supreme Court.

The “gay panic” or “trans panic” defense involves arguing that a victim’s sexual orientation or gender identity was so upsetting that a defendant was incapable of controlling themselves or considering the consequences of their actions. Alternatively, a defendant may argue that a victim’s LGBTQ identity made them fear for their safety or life, thereby justifying an act of violence in “self-defense.”

Although the American Bar Association has called for banning “panic” defenses, they have been used in high-profile cases involving LGBTQ murder victims, including Matthew Shepard, Brandon Teena, Marco McMillan, Gwen Araujo, Angie Zapata, and Islan Nettles.