State of Tennessee v. Coynick Boswell, W2016-02591-CCA-R3-CD

Defendant Coynick Boswell confronted victim Kadrian Woods on an apartment stairway after accusing him of passing counterfeit money; Boswell was armed.
Three eyewitnesses (Brandon Sails, Wardell Thomas, Carlos Daniel) testified and later identified Boswell as the shooter. Their accounts conflicted on who was the initial aggressor and who controlled the gun during the struggle.
The victim sustained two gunshot wounds; the medical examiner testified one wound (to the back) was inflicted at close range and caused rapid death.
Boswell requested a jury instruction on self-defense; the trial court denied it. The jury was instructed on first-degree murder and lesser included offenses and found Boswell guilty of first-degree murder.
Boswell appealed, challenging (1) the sufficiency of evidence for premeditated murder and (2) the trial court’s refusal to instruct on self-defense. The Court of Criminal Appeals reversed and remanded for a new trial, concluding the court erred in failing to give the self-defense instruction while finding the evidence was sufficient to support premeditation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing a self-defense jury instruction	State: Defendant was the primary aggressor; testimony supported withholding instruction	Boswell: Evidence fairly raised self-defense because victim lunged for gun and threatened to throw defendant over balcony	Reversed and remanded — self-defense was fairly raised; court must instruct jury on self-defense
Whether evidence was sufficient to support conviction for premeditated (first-degree) murder	State: Eyewitness IDs, multiple shots including a close-range shot to the back, flight and failure to render aid support premeditation	Boswell: No proof of preexisting intent; carrying a gun for safety and a chance encounter negate premeditation	Affirmed on sufficiency — evidence was sufficient for a rational jury to find intent and premeditation

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (factors supporting premeditation)
State v. Halake, 102 S.W.3d 661 (Tenn. Crim. App. 2001) (multiple shots may support inference of premeditation)
State v. Hawkins, 406 S.W.3d 121 (Tenn. 2013) (standard for when a trial court must give a defensive instruction)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (sufficiency standard for circumstantial and direct evidence)
Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (jury as primary factfinder; credibility and weight of evidence)