Rodney Watkins v. State of Tennessee
W2016-00075-CCA-R3-PC
| Tenn. Crim. App. | Mar 2, 2017Background
- Rodney Watkins was convicted by a Shelby County jury in 2009 of second-degree murder and sentenced to 25 years; conviction affirmed on direct appeal.
- Victim Lamika Turner disappeared Feb 3, 2009; her badly decomposed body was found in an abandoned house next to Watkins’ home; cause of death blunt force trauma to the head.
- Watkins initially blamed others, then gave a statement describing being at the scene, picking up a cinder block, and striking the victim during a struggle involving a man nicknamed “Benzo.”
- The State had offered Watkins a 15-year plea; he declined. Defense theory at trial focused on identity/unknown assailant and challenging voluntariness of Watkins’ statement rather than an accidental-strike defense.
- Post-conviction petition (filed pro se, later amended) claimed ineffective assistance of counsel for (1) failing to pursue an accidental-killing defense and (2) not calling witness Ronald Burgess, who had observed events that night.
- At the evidentiary hearing, trial counsel testified the accidental-strike theory was implausible, lacked expert support, and Burgess’s potential testimony was inculpatory; the post-conviction court credited counsel and denied relief.
Issues
| Issue | Watkins' Argument | State's Argument | Held |
|---|---|---|---|
| Ineffective assistance for not pursuing accidental-killing defense | Counsel was deficient for refusing to press an accidental-strike defense | Counsel made a reasonable strategic choice to pursue identity/voluntariness issues instead of an implausible accidental theory | Denied — strategy was reasonable; petitioner failed to show deficiency or prejudice |
| Ineffective assistance for not calling Ronald Burgess | Counsel should have called Burgess whose testimony would support innocence | Burgess’s testimony was inculpatory and counsel reasonably declined to call him | Denied — trial counsel reasonably excluded Burgess; no prejudice shown |
Key Cases Cited
- Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (standard for attorney competence in criminal cases)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: performance and prejudice)
- Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (post-conviction factual findings entitled to deference)
- Kendrick v. State, 454 S.W.3d 450 (Tenn. 2015) (strong presumption counsel used reasonable professional judgment)