State of Tennessee v. Christopher Lynn Clark
W2015-01579-CCA-R3-CD
| Tenn. Crim. App. | Aug 15, 2016Background
- Defendant Christopher L. Clark was convicted by an Obion County jury of vehicular homicide by intoxication and four counts of vehicular assault with intoxication; sentences were run concurrently for an effective 10-year term.
- The crash occurred on August 30, 2013 on Chapel Hill Road, Obion County, after the Tahoe driven by Clark sped, passed in a no-passing zone, clipped a culvert, and flipped, killing a fourteen-year-old passenger and injuring others.
- Witnesses described Clark as intoxicated, with slurred speech and glassy eyes, while controlling the vehicle and pressuring others to drive.
- Blood testing revealed diazepam, nordiazepam, alprazolam, and tramadol; defense argued potential lab mix-up, while the State relied on expert testimony linking CNS depressants to impairment.
- The trial court instructed the jury regarding blood-sample integrity after a defense expert suggested testing irregularities; the court stated there was no proof of a mix-up, which the defense argues was error but was waived on appeal.
- On appeal, Clark challenged sufficiency of evidence, trial-court comments on evidence, and the sentence; the Tennessee Court of Criminal Appeals upheld the convictions and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence | Clark argues insufficient proof of intoxication and impairment. | Clark contends the State failed to show impairment caused the crashes. | Sufficiency established; jury could find intoxication and impairment beyond reasonable doubt. |
| Trial court comments on evidence | Clark claims the court improperly commented on evidence via a blood-sample mix-up instruction. | Clark asserts trial court erred and that commentary affected the verdict. | Waived; no plain error shown; instruction not reversible. |
| Sentence within statutory range | Clark asserts the two-year excess over the minimum is excessive. | Clark argues the sentence departed from the purposes of sentencing. | No abuse of discretion; within range and supported by evidence. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of evidence)
- Goodwin v. State, 143 S.W.3d 771 (Tenn. 2004) (strength of evidence standard in sufficiency review)
- State v. Reid, 91 S.W.3d 247 (Tenn. 2002) (credibility and circumstantial evidence guidance)
- State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (circumstantial evidence standard; credibility)
- State v. Rice, 184 S.W.3d 646 (Tenn. 2006) (weight given to circumstantial evidence)
- State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (credibility and weight of witness testimony)
- State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (jury weighs credibility; standard of review)
- State v. Barone, 852 S.W.2d 216 (Tenn. 1993) (general sufficiency and credibility framework)
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse-of-discretion sentencing standard)
- State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (range and purpose of sentencing; factor analysis)
- State v. Shaffer, 45 S.W.3d 553 (Tenn. 2001) (enhancement/mitigation factors in sentencing)
- State v. Hester, 324 S.W.3d 788 (Tenn. 2010) (plain-error review and substantial justice)
- State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (presumption of reasonableness in sentencing)
