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State of Tennessee v. Christopher Lynn Clark
W2015-01579-CCA-R3-CD
| Tenn. Crim. App. | Aug 15, 2016
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Background

  • 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)
Read the full case

Case Details

Case Name: State of Tennessee v. Christopher Lynn Clark
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Aug 15, 2016
Docket Number: W2015-01579-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.