State of Tennessee v. Brendan T. Negron
M2024-00257-CCA-R3-CD
Tenn. Crim. App.Jun 5, 2025Background
- Brendan T. Negron was convicted by a Wilson County, Tennessee jury of aggravated domestic assault against his wife in 2020, based on the use of a heavy, wrought iron barstool.
- The victim testified Negron threw a barstool that knocked her down, then struck her and threatened to kill her.
- Negron argued on appeal that the barstool was not a deadly weapon under Tennessee law and disputed his intent to cause serious harm.
- The trial court sentenced Negron to five years on supervised probation; he appealed, seeking a reduction to misdemeanor domestic assault.
- The appellate court considered whether the evidence was legally sufficient to establish assault with a deadly weapon, focusing on the statutory definitions and the manner of use.
Issues
| Issue | Negron's Argument | State's Argument | Held |
|---|---|---|---|
| Was the barstool a "deadly weapon" as used? | Barstool not used or intended to inflict death/serious injury. | Heavy barstool, manner of use could cause death/serious injury. | Affirmed conviction; jury could reasonably find barstool was used as deadly weapon. |
| Was the evidence sufficient for aggravated assault? | Should reduce to misdemeanor domestic assault; no deadly weapon used. | All elements of aggravated assault met, including use of deadly weapon. | Evidence was sufficient; conviction upheld. |
Key Cases Cited
- State v. McGouey, 229 S.W.3d 668 (Tenn. 2007) (item only considered a deadly weapon if actually used or intended to cause death/serious injury in the particular case)
- State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (appellate courts do not reweigh or reevaluate evidence; credibility determined by trier of fact)
- State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (jury verdict entitles State to strongest legitimate view of trial evidence)
- State v. Grace, 493 S.W.2d 474 (Tenn. 1973) (jury resolves conflicts and determines credibility of witnesses)
- Morgan v. State, 415 S.W.2d 879 (Tenn. 1967) (discusses definition and categories of deadly weapons)
