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