State of Tennessee v. April Lamb, M2016-00461-CCA-R3-CD

On Nov. 8, 2013, police responded after April Lamb drove to a parking lot and reported an assault by her then-husband, Jeremy Lamb; she appeared intoxicated and sought to know whether he would be arrested.
Officer Collins found Jeremy at the residence with a large bloody knot on his head, a cut over his eye, bleeding from his arm, and a bite mark; photos, an iron skillet (~8–10 lbs), and a folding knife were introduced.
Jeremy said April struck him with a skillet while he was sleeping and stabbed him; April admitted hitting him with a skillet but claimed she acted in self‑defense after Jeremy allegedly assaulted, choked, and dragged her.
April was charged with two counts of aggravated assault and two counts of domestic assault; the jury convicted her of one count of aggravated assault (use of a skillet as a deadly weapon) and acquitted on the other counts.
The trial court sentenced April to four years (standard range), suspended to supervised probation; she appealed challenging sufficiency of the evidence and admission of character testimony.

Issue	State's Argument	Lamb's Argument	Held
Sufficiency of the evidence for aggravated assault by use of a deadly weapon	Evidence showed April knowingly caused injury by striking Jeremy with a heavy skillet; jury credibility findings must stand	Evidence insufficient: no proof of serious bodily injury; skillet not shown to have been used as a deadly weapon; self‑defense raised reasonable doubt	Affirmed. The skillet was capable of causing serious injury and, viewing evidence in State’s favor, a rational jury could convict; jury rejected self‑defense testimony
Admissibility of victim‑character testimony (rebuttal witness Lori Ward)	Ward’s testimony about victim’s peacefulness was admissible rebuttal of credibility/character implications	Trial court erred by allowing State to present character evidence while excluding defense evidence of victim’s bad acts; alternatively, both sides should have been allowed similar character proof	Affirmed in part: defendant waived specific appellate objection by objecting only on relevance at trial; court properly limited the questioning and sustained relevance objection

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (sufficiency review applies to direct and circumstantial evidence)
State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (credibility and weight of evidence are for the jury)
State v. Winters, 137 S.W.3d 641 (Tenn. Crim. App. 2003) (application of Jackson sufficiency standard)
State v. Adkisson, 899 S.W.2d 626 (Tenn. Crim. App. 1994) (party cannot assert a new theory on appeal that was not raised at trial)
State v. Aucoin, 756 S.W.2d 705 (Tenn. Crim. App. 1988) (same principle regarding preservation of issues for appellate review)