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State of Tennessee v. Carl Adkins
W2015-01810-CCA-R3-CD
| Tenn. Crim. App. | May 24, 2017
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Background

  • Defendant Carl Adkins (step‑father) was convicted by a jury of rape of a child and sentenced to 25 years in the Tennessee Department of Correction.
  • Victim was nearly five at the time of the disclosed conduct and about six at trial; she gave a recorded forensic interview describing oral contact and ejaculation by "Daddy Carl."
  • Forensic interviewer and investigator testified; the recorded interview was admitted into evidence under T.C.A. § 24‑7‑123.
  • The victim described that "Daddy Carl" lived in the same house, was married to her mother, and had a secret "kissy"/"kissing game" involving the child and his genital area; she demonstrated the acts in the forensic interview.
  • At trial the victim could not identify Adkins in the courtroom and gave some testimony referencing other adults (e.g., biological father), but investigators corroborated that Adkins lived with the victim and was the person investigated and charged.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sufficiency of the evidence to prove identity and rape of a child State: recorded interview, victim testimony, and investigation establish that "Daddy Carl" (Adkins) committed sexual penetration of the child Adkins: victim could not identify him in court and gave contradictory testimony, so evidence is insufficient Court: Affirmed conviction; viewing evidence in State's favor, direct and circumstantial evidence (including forensic interview and investigator testimony) sufficiently proved identity and elements of rape of a child

Key Cases Cited

  • Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
  • State v. Goodwin, 143 S.W.3d 771 (Tenn. 2004) (appellate standard: do not reweigh evidence)
  • State v. Elkins, 102 S.W.3d 578 (Tenn. 2003) (afford prosecution strongest legitimate view and reasonable inferences)
  • State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (jury verdict accredits State witnesses; resolves conflicts for prosecution)
  • State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on accused to show insufficiency after conviction)
  • State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same standard applies to circumstantial and direct evidence)
  • State v. Wagner, 382 S.W.3d 289 (Tenn. 2012) (circumstantial evidence may suffice without excluding every reasonable hypothesis)
  • State v. Rice, 184 S.W.3d 646 (Tenn. 2006) (identity is an essential element; may be proven circumstantially)
  • State v. Lewter, 313 S.W.3d 745 (Tenn. 2010) (identity may rest solely on circumstantial evidence)
  • State v. Strickland, 885 S.W.2d 85 (Tenn. Crim. App. 1993) (identity is a jury question)
  • State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (inconsistencies in testimony are for jury to resolve)
Read the full case

Case Details

Case Name: State of Tennessee v. Carl Adkins
Court Name: Court of Criminal Appeals of Tennessee
Date Published: May 24, 2017
Docket Number: W2015-01810-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.