History
  • No items yet
midpage
State of Tennessee v. Alonzo Christopher Downey
M2017-00304-CCA-R3-CD
| Tenn. Crim. App. | Sep 7, 2017
Read the full case

Background

  • Victim Elishia Cheathem and defendant Alonzo Downey were dating and living together; incident alleged to have occurred Aug. 15, 2014.
  • After an argument about Downey being late and allegedly cheating, Cheathem hid Downey’s phone.
  • Cheathem testified Downey grabbed both her arms, lifted/jerked her from the couch, and she fell to the floor, suffering pain and bruises.
  • Cheathem called 911 two days later; officers observed and photographed bruises and prepared a domestic violence report; an arrest warrant issued.
  • Downey testified the events occurred earlier (not on Aug. 15), denied assaulting Cheathem as described, and said any contact was pulling her away from a door; trial court credited victim’s testimony.
  • Bench trial conviction for domestic assault; Downey sentenced to 11 months, 29 days probation and appealed on sufficiency grounds.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence to support domestic assault conviction State: Evidence (victim’s testimony, 911 call, photos of bruises, officer report) permits a rational factfinder to find assault beyond a reasonable doubt Downey: Victim’s timeline inconsistent; contact was minimal or earlier; bruises preexisted or resulted from different incident; credibility challenges Affirmed — when viewed in the light most favorable to the State, evidence was sufficient to support conviction

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
  • State v. Goodwin, 143 S.W.3d 771 (Tenn. 2004) (appellate standard for sufficiency review)
  • State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same standard applies to circumstantial evidence)
  • State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (credibility and weight of evidence are for the trier of fact)
  • State v. Grace, 493 S.W.2d 474 (Tenn. 1973) (verdict accredits State witnesses)
Read the full case

Case Details

Case Name: State of Tennessee v. Alonzo Christopher Downey
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Sep 7, 2017
Docket Number: M2017-00304-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.