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State of Tennessee v. Carl J. Wagner
2012 Tenn. LEXIS 746
Tenn.
2012
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Background

  • In August 2008, Wagner shot Adriel Powell in a Nashville apartment laundry room during an alleged drug deal.
  • The State charged Wagner with premeditated first degree murder, first degree felony murder, and especially aggravated robbery.
  • Police recovered physical and DNA evidence linking Wagner to the crime, including bloodstains matching Wagner and Powell, and a firearm-related evidentiary trail.
  • Wagner provided an interview at Vanderbilt Hospital in which he admitted carrying a .45 caliber handgun and described events leading to the shooting.
  • The jury convicted Wagner of felony murder, especially aggravated robbery, and second degree murder; the latter merged with felony murder, yielding life for felony murder and 22 years for the robbery.
  • The Court of Criminal Appeals reversed, finding the evidence insufficient for especially aggravated robbery, prompting the State to appeal to determine sufficiency under Tennessee law.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the evidence suffices for especially aggravated robbery State contends the circumstantial proof plus Wagner's confession establish taking of the backpack Wagner argues lack of corroboration of the backpack taking makes the conviction improper Yes; sufficient evidence supports the conviction for especially aggravated robbery
Whether the evidence suffices for felony murder State argues there was a causal link between the robbery attempt and the killing Wagner contends self-defense or mutual combat negates intent to commit robbery Yes; sufficient evidence supports felony murder

Key Cases Cited

  • Dorantes v. State, 331 S.W.3d 370 (Tenn. 2011) (circumstantial evidence can support a conviction; corpus delicti concerns still apply)
  • Banks v. State, 271 S.W.3d 90 (Tenn. 2008) (corpus delicti requires corroboration for confessions)
  • Housler v. State, 193 S.W.3d 476 (Tenn. 2006) (corpus delicti and corroboration principles in Tennessee)
  • Smith v. State, 24 S.W.3d 274 (Tenn. 2000) (corroboration rule in confession cases)
  • Ashby v. State, 139 S.W.3d 872 (Tenn. 1911) (early corpus delicti guidance on corroboration)
  • Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for evaluating sufficiency of convicting evidence)
  • State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (limits on weighing evidence on appeal; jury credibility)
  • State v. Parker, 350 S.W.3d 883 (Tenn. 2011) (standard of review for sufficiency of evidence)
  • State v. Pierce, 23 S.W.3d 289 (Tenn. 2000) (temporal/continuity connection in felony murder)
  • State v. Buggs, 995 S.W.2d 102 (Tenn. 1999) (timing/connection in felony murder)
Read the full case

Case Details

Case Name: State of Tennessee v. Carl J. Wagner
Court Name: Tennessee Supreme Court
Date Published: Oct 12, 2012
Citation: 2012 Tenn. LEXIS 746
Docket Number: M2010-00992-SC-R11-CD
Court Abbreviation: Tenn.