State of Tennessee v. Antonio Richardson, W2016-00340-CCA-R3-CD

Victim Andrew "Woo" Wooten was shot multiple times while sitting in his car at Thompson Court Apartments on August 16, 2014 and later died from his wounds.
Witnesses (apartment residents and surveillance video) placed a black Pontiac Aztec registered to Antonio Richardson at the scene; several witnesses identified a man shooting from that vehicle and then walking up to the victim’s car and continuing to fire.
Seventeen 9mm cartridge casings were recovered near the scene; the victim was unarmed and marijuana was found in his car.
Richardson admitted at trial that he fired a 9mm handgun at the victim, that he parked behind a bush before exiting his SUV, and that he fired multiple shots; he claimed self-defense based on a prior 2012 incident in which the victim shot him.
The jury convicted Richardson of first-degree premeditated murder; the trial court imposed a life sentence. Richardson appealed, challenging (1) sufficiency of the evidence/premeditation and provocation and (2) admission of a crime-scene photograph of the victim in the driver’s seat.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency / Premeditation	State: evidence (surveillance, witnesses, casings, flight, SUV ownership) permits inference of intent and premeditation	Richardson: acted under adequate provocation or in sudden heat of passion/self-defense due to prior 2012 shooting and threats that day; verdict should be reduced to manslaughter	Conviction affirmed; jury reasonably found premeditation and rejected self-defense/provocation; evidence sufficient for first-degree murder
Admissibility of photograph	State: photo showing victim slumped in driver’s seat (no weapon visible) was relevant to location/position of body and to rebut self-defense; probative value not substantially outweighed by prejudice	Richardson: photo was gruesome, cumulative, possibly taken after paramedic contact and thus inaccurate as to position; should have been excluded under Rule 403	Admission not an abuse of discretion; photo was relevant to disputed issues, not overly gruesome, and aided jurors in assessing premeditation/self-defense claims

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review)
State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (appellate standard for viewing evidence in light most favorable to State)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (circumstantial-evidence sufficiency standard)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (factors supporting premeditation and deliberation)
State v. Banks, 564 S.W.2d 947 (Tenn. 1978) (admissibility of gruesome photos in murder prosecutions)
State v. Dotson, 450 S.W.3d 1 (Tenn. 2014) (definition of unfair prejudice under Rule 403)