State of Tennessee v. Chad Ray Thompson
M2015-01534-CCA-R3-CD
Tenn. Crim. App.Dec 1, 2016Background
- Defendant Chad Ray Thompson was indicted for first-degree premeditated murder, first-degree felony murder, and especially aggravated robbery in the death of his cousin Tracy Martin; jury convicted him of first-degree premeditated murder, first-degree felony murder (merged), and facilitation of especially aggravated robbery; effective sentence: life.
- Victim received a lump-sum Social Security payment; shortly before disappearance he had cash, a handgun, and purchased .38 ammunition; victim was later found in a river with blunt-force injuries to the back of his head.
- Witnesses (Cobb, Muncey) testified Thompson solicited them to help rob the victim, then threatened to kill him when they refused; Thompson sold or arranged sale/transfer of a .38 revolver shortly after the solicitation.
- A sledge hammer with the name "Nina" (Defendant’s girlfriend) scratched on it was found near Muncey’s apartment; presumptive blood test was positive; autopsy described blunt force semicircular injuries consistent with a heavy circular object.
- Recorded jail calls and letters showed Defendant urging removal of an item from woods and referencing that the item had his girlfriend’s name on it; Defendant also demonstrated knowledge of crime-scene details and displayed nervous/furtive behavior during the investigation.
Issues
| Issue | State's Argument | Thompson's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence of premeditation for first-degree murder | Evidence of prior statements to kill, procurement/possession of a weapon, repeated blows to back of head, hammer with girlfriend’s name, and attempts to conceal support premeditation | Insufficient proof that killing was premeditated; testimony from Cobb/Muncey unreliable/self-serving | Affirmed — evidence sufficient to support premeditation conviction |
| Sufficiency of evidence that killing occurred during perpetration of robbery (felony murder underlying robbery) | Defendant planned robbery of victim’s disability funds, solicited assistance, arranged to sell a .38 shortly after, had unusually large cash, victim missing money and gun — supports that killing occurred in perpetration of robbery | Insufficient proof of completed or attempted robbery as underlying felony for felony murder | Affirmed — evidence supported intent to steal by violence and that victim died in perpetration of robbery |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
- State v. Cabbage, 571 S.W.2d 832 (credibility and weight of evidence are for the jury)
- State v. Dorantes, 331 S.W.3d 370 (same standard for circumstantial evidence)
- State v. Bland, 958 S.W.2d 651 (jury verdict replaces presumption of innocence)
- State v. Vasques, 221 S.W.3d 514 (State entitled to strongest legitimate view of evidence)
- State v. Larkin, 443 S.W.3d 751 (circumstantial factors probative of premeditation)
- State v. Thacker, 164 S.W.3d 208 (list of factors probative of premeditation)
- State v. Lewis, 36 S.W.3d 88 (factors relevant to premeditation)
