State of Tennessee v. Buford Cornell Williams, M2017-00507-CCA-R3-CD

Defendant Buford Cornell Williams was indicted for selling 0.5 grams or more of cocaine (Class B felony) and waived a jury trial; the bench convicted him and sentenced him to 14 years.
Police conducted a controlled buy using a very reliable confidential informant at a carwash parking lot; the informant contacted William Thomas, who later interacted with Defendant after Defendant arrived.
Minutes after Defendant's arrival and an observed interaction between Defendant and Thomas, the confidential informant received a white rock later lab-tested as 0.64 grams of cocaine base.
The informant handed the cocaine to an arresting sergeant and had been searched and given photocopied bills before the buy; at arrest, Defendant had $50 in his pocket matching the photocopied buy money.
Defendant testified he was there to get chicken and give Thomas a ride, claimed Thomas showed him drugs and paid him the $50 he was owed; the trial court discredited this explanation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to convict for sale of ≥0.5 g cocaine	Evidence shows timing/inferences: cocaine in informant’s possession minutes after Defendant arrived and buy money found on Defendant — supports inference Defendant supplied/sold the cocaine	Defendant argued no direct evidence he was party to the sale and offered a plausible innocent explanation (getting chicken, being paid money owed)	Court held evidence (circumstantial) was sufficient; a rational trier of fact could find beyond a reasonable doubt that Defendant knowingly sold 0.5+ grams of cocaine
Credibility/weight of evidence on appeal	State: trial court rejected Defendant’s story; credibility resolved by trier of fact	Defendant: asked appellate court to credit his testimony and alternative explanation	Court declined to reweigh credibility; appellate review limited to whether any rational trier of fact could convict (standard applied)

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 standard applies equally to circumstantial and direct evidence)
State v. Farrar, 355 S.W.3d 582 (Tenn. Crim. App. 2011) (bench trial verdict entitled to same weight on appeal as jury verdict)
State v. Elkins, 102 S.W.3d 578 (Tenn. 2003) (appellate courts must view evidence in the strongest legitimate light for the State)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (appellate courts will not re-evaluate witness credibility)