State of Tennessee v. Christopher Collier
W2016-01231-CCA-R3-CD
| Tenn. Crim. App. | Jun 20, 2017Background
- Christopher Collier was tried by a Shelby County jury for theft of property valued between $1,000 and $10,000 after lawn-equipment and a trailer belonging to Kenneth Knox were taken on May 15, 2014.
- Witness Roderick Smith observed two men near Knox’s trailer after midnight, saw them enter a white SUV hauling the trailer, and reported the vehicle to police promptly.
- Officers stopped the white SUV a short distance away; Collier was in the back seat, another occupant fled and was arrested, and a large set of bolt cutters was found inside the vehicle.
- Knox identified the recovered trailer and equipment as his and testified he had not given permission to remove them; the property’s value exceeded $1,000.
- A jury convicted Collier of theft (Class D felony), and the trial court sentenced him to 12 years as a persistent offender; Collier appealed, arguing insufficient evidence of intent to deprive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove intent to deprive owner of property | State: Circumstantial evidence (nighttime takings, rapid departure, bolt cutters, possession in vehicle) supports inference of intent and knowing control | Collier: Evidence insufficient to prove intent beyond a reasonable doubt; asks court to reweigh circumstantial inferences | Affirmed: Viewing evidence in light most favorable to State, a rational juror could find intent beyond a reasonable doubt |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
- State v. Elkins, 102 S.W.3d 578 (State entitled to strongest legitimate view of evidence on appeal)
- State v. Smith, 24 S.W.3d 274 (same principle cited regarding appellate review)
- State v. Bland, 958 S.W.2d 651 (credibility and weight of evidence are jury functions)
- State v. Matthews, 805 S.W.2d 776 (appellate court will not reweigh evidence)
- State v. Dorantes, 331 S.W.3d 370 (circumstantial evidence standard equals direct evidence standard)
- State v. Wagner, 382 S.W.3d 289 (circumstantial evidence may alone support conviction)
- State v. Tuggle, 639 S.W.2d 913 (burden shifts to defendant on sufficiency claim after conviction)