AN ALIBI, IN ADDITION TO BEING ONE OF THE BEST MEANS OF EXCULPATING THE INNOCENT, IS ALSO ONE OF THE BEST PLOYS OF THE GUILTY. THE COURTS HAVE LONG BEEN AWARE OF THE POTENTIAL FOR ABUSE AND HAVE OBSERVED THAT THE ALIBI OFTEN IS USED TO DECEIVE THE JURY. NEVERTHELESS, MOST JURISDICTIONS HOLD THAT INSTRUCTIONS DISPARAGING AN ALIBI ARE IMPERMISSIBLE. TRADITIONALLY, THE TENNESSEE SUPREME COURT APPROVED JURY INSTRUCTIONS THAT DISPARAGED A DEFENDANT'S ALIBI, INCLUDING THOSE CHARACTERIZING THE ALIBI AS EASILY CONCOCTED OR ABUSED OR STATING THAT THE EVIDENCE SHOULD BE RECEIVED WITH CAUTION. HOWEVER, UNTIL THE CASE OF CHRISTIAN V. TENNESSEE, THESE INSTRUCTIONS HAD NOT BEEN EVALUATED SERIOUSLY IN THE CONTEXT OF THE STATE CONSTITUTIONAL PROHIBITION AGAINST COMMENT UPON THE EVIDENCE BY THE TRIAL JUDGE. IN CHRISTIAN, THE COURT HELD THAT THE CHARGE IN THE INSTANT CASE CONSTITUTED HARMLESS ERROR BUT STATED THAT JURY INSTRUCTIONS BY TENNESSEE TRIAL JUDGES IN THE FUTURE MAY NOT CONTAIN DISPARAGING REMARKS ABOUT THE DEFENDANT'S ALIBI. THE TRIAL COURT MAY CONTINUE TO INSTRUCT GENERALLY ON THE ALIBI WHEN THE ISSUE IS RAISED BUT MAY NOT DISPARAGE THE ALIBI OR INSTRUCT THE JURY TO TREAT THE ALIBI DIFFERENTLY FROM OTHER EVIDENCE. THE CHRISTIAN DECISION BRINGS TENNESSEE INTO LINE WITH MOST OTHER JURISDICTIONS AND PROVIDES SPECIFIC GUIDELINES TO THE LOWER COURTS. HOWEVER, IN LIGHT OF THE PEJORATIVE CONNOTATION THAT THE TERM 'ALIBI' HAS TAKEN ON, IT MAY BE NECESSARY TO ELIMINATE THE TERM FROM THE JURY INSTRUCTION. REFERENCES ARE FOOTNOTED. (LKM)