State of Tennessee v. Alonzo Christopher Downey
M2017-00304-CCA-R3-CD
| Tenn. Crim. App. | Sep 7, 2017Background
- 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)
