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State of Tennessee v. Bryant Christopher Mitchell
E2020-01689-CCA-R3-CD
| Tenn. Crim. App. | Oct 13, 2021
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Background

  • November 2016: 17‑year‑old Caleb Arwood was found in an alley in Knoxville with approximately 18 gunshot wounds and pronounced dead at the scene.
  • Witnesses placed Bryant Christopher Mitchell as a passenger in a silver Chevrolet Cobalt the night of the killing; witnesses observed him with a firearm equipped with an extended magazine.
  • Multiple witnesses (including passengers and a nearby resident) testified Mitchell exited the car, shot the victim twice, then returned minutes later and fired many additional rounds at point‑blank range.
  • Crime‑scene recovery included a cell phone near the body linked to Mitchell’s online alias, an extended Glock magazine with live cartridges, 17 fired cartridge cases (all fired from the same 9mm), and bullet fragments; some autopsy wounds showed close‑range firing characteristics.
  • Officers recovered black pants from the apartment where Mitchell was staying; the pants contained a mixture of DNA with Mitchell as a major contributor and tested positive for gunshot residue. Mitchell fled police, was captured, and was interviewed at the station (refused to sign waiver but agreed to talk).
  • At trial the jury convicted Mitchell of first‑degree (premeditated) murder; he appealed arguing insufficiency of the evidence and witness inconsistencies.

Issues

Issue Plaintiff's Argument (State) Defendant's Argument (Mitchell) Held
Sufficiency of the evidence to support first‑degree murder (identity and premeditation) Eyewitness testimony placed Mitchell at the scene with a gun, cell phone tied to his alias found by the body, extended Glock magazine at scene, 9mm casings from same gun, pants with Mitchell's DNA and GSR; circumstantial proof supports identity and premeditation Witness accounts contained discrepancies; no direct scientific link tying Mitchell to the magazine/bullets; no proof he wore the pants the night of the shooting Affirmed. Viewing evidence in the light most favorable to the State, a rational juror could find identity and premeditation beyond a reasonable doubt; credibility resolved by jury
Waiver based on inadequate appellant brief Argued Mitchell’s sufficiency argument was waived for lack of adequate record citations in his brief Mitchel argued the brief included enough factual citations to permit review Court noted briefing deficiencies but exercised discretion to address the merits and denied relief

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
  • State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (apply strongest legitimate view of the evidence in sufficiency review)
  • State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (inferences drawn in favor of the State)
  • State v. Bell, 512 S.W.3d 167 (Tenn. 2015) (identity may be proved with circumstantial evidence)
  • State v. Rice, 184 S.W.3d 646 (Tenn. 2006) (circumstantial evidence can establish identity)
  • State v. Sims, 45 S.W.3d 1 (Tenn. 2001) (definition and proof of premeditation)
  • State v. Leach, 148 S.W.3d 42 (Tenn. 2004) (circumstantial factors probative of premeditation)
  • State v. Kiser, 284 S.W.3d 227 (Tenn. 2009) (factors for inferring premeditation)
Read the full case

Case Details

Case Name: State of Tennessee v. Bryant Christopher Mitchell
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Oct 13, 2021
Docket Number: E2020-01689-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.