State of Tennessee v. Christopher Lee Williams, M2016-00568-CCA-R3-CD

Christopher Lee Williams and his live-in girlfriend, Jessica Head, had a violent altercation on Sept. 8, 2014; Head was thrown to the floor, struck, pinned face-down on carpet (unable to breathe for minutes), and later prevented from leaving to obtain medical care.
Head retreated upstairs to assess injuries; when she attempted to leave for help or the hospital, Williams allegedly grabbed her at doors, threw her against walls/furniture, and kept her confined overnight; she left the next morning to get her paycheck and did not return.
Williams was indicted for aggravated assault by strangulation, especially aggravated kidnapping with serious bodily injury, and domestic assault with bodily injury; the jury convicted him of reckless endangerment (lesser), aggravated kidnapping (lesser), and domestic assault.
At trial the court gave the White instruction (jury must find removal/confinement had independent criminal significance beyond the underlying felony); the State argued assault supported the domestic-assault conviction and the subsequent confinement/prevention from leaving supported aggravated kidnapping.
Williams was sentenced to an effective ten-year term. On appeal he challenged (1) the propriety of dual convictions for aggravated kidnapping and domestic assault when both relied on bodily injury, and (2) the trial court’s failure to apply the statutory mitigating factor for voluntary release at sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dual convictions (aggravated kidnapping with bodily injury + domestic assault with bodily injury) were proper	State: jury was given White instruction and elected discrete facts for each offense; evidence shows separate assault and later confinement preventing Head from leaving	Williams: both convictions rely on the same bodily injury; removal/confinement was incidental to the assault, so dual convictions improper	Affirmed. Jury reasonably found confinement had independent criminal significance beyond the assault under White; dual convictions allowed
Whether trial court erred by not applying statutory mitigating factor for voluntary release at sentencing	State: even if factor applies, sentence is within range and complies with Sentencing Act; any omission is harmless	Williams: victim was eventually released (left next morning), so court should have applied mitigating factor under Tenn. Code Ann. § 39-13-305(b)(2)	Affirmed. Trial court arguably should have applied the factor, but omission did not require relief because sentence was within-range and not contrary to sentencing principles

Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-the-evidence standard)
State v. White, 362 S.W.3d 559 (Tenn. 2012) (kidnapping requires removal/confinement with criminal significance beyond an accompanying felony; jury instruction required)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (standard for appellate review of within-range sentencing; presumption of reasonableness)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (jury verdict resolves witness credibility and conflicts in proof)