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State of Tennessee v. Anthony Lebron Vance
E2020-00467-CCA-R3-CD
| Tenn. Crim. App. | Jul 12, 2021
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Background

  • On Jan. 3, 2018, a woman walking home from a bus stop was approached, forced behind a duplex, and sexually assaulted; she suffered injuries and bleeding and was hospitalized.
  • Victim identified the assailant in a photo lineup; a nearby neighbor saw the man flee and identified him as the Defendant, Anthony Vance.
  • GPS monitoring placed Vance in the vicinity of the assault during the relevant time window; TBI testing matched Vance’s DNA to saliva on the victim’s left nipple.
  • At trial Vance denied being in the area; he was convicted by a jury of rape and sentenced to 25 years (100%), ordered consecutive to a prior 10-year sentence (effective 35 years).
  • On appeal to the Tennessee Court of Criminal Appeals, Vance challenged (1) sufficiency of the evidence and (2) the imposition of consecutive sentencing.
  • The court affirmed: evidence (victim testimony + forensic and GPS corroboration) was sufficient; consecutive sentence upheld because the offense occurred while Vance was on probation and the court did not abuse its discretion.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence State: Victim’s testimony corroborated by forensic injuries, DNA, GPS, and eyewitness ID supports conviction Vance: Victim’s testimony was inconsistent, invoking the cancellation rule; evidence uncorroborated Affirmed — viewed in light most favorable to State, evidence (including DNA, injuries, GPS, eyewitness) was sufficient
Consecutive sentencing State: Trial court properly exercised discretion; consecutive term authorized because offense committed while on probation Vance: Effective 35-year sentence is excessive (near-life given age and limited credits) Affirmed — court did not abuse discretion; probationary status justified consecutive sentence and sentence was not greater than deserved

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review)
  • Bland v. State, 958 S.W.2d 651 (Tenn. 1997) (credibility and weight of evidence are jury functions)
  • Matthews v. State, 888 S.W.2d 446 (Tenn. Crim. App. 1993) (rule of cancellation for contradictory testimony)
  • Dorantes v. State, 331 S.W.3d 370 (Tenn. 2011) (circumstantial and direct evidence treated the same for sufficiency review)
  • Bise v. State, 380 S.W.3d 682 (Tenn. 2012) (abuse-of-discretion standard with presumption of reasonableness for within-range sentences)
  • Pollard v. State, 432 S.W.3d 851 (Tenn. 2013) (broad trial-court discretion on consecutive sentencing)
  • Desirey v. State, 909 S.W.2d 20 (Tenn. Crim. App. 1995) (consecutive sentence must be no greater than deserved and least severe necessary)
  • Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (appellate standard reiterating Jackson sufficiency review)
Read the full case

Case Details

Case Name: State of Tennessee v. Anthony Lebron Vance
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Jul 12, 2021
Docket Number: E2020-00467-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.