State of Tennessee v. Darin Woods, W2016-01486-CCA-R3-CD

On April 18, 2014, Darin Woods and co-defendant Rodney Fleming lured Devin and Dedrick Bradley to an apartment complex under the pretext of selling a PlayStation 4 and television.
At the complex Woods produced a gun, demanded money and car keys, and ordered the brothers to the ground; the brothers fled instead.
Woods fired multiple shots as the brothers ran; Devin was struck in the back. Devin identified Woods as his shooter; Malone and other witnesses placed Woods at the scene.
Woods denied participation at trial, claiming memory issues and that Malone falsely implicated him.
A jury convicted Woods of aggravated robbery, attempted aggravated robbery, employing a firearm during a dangerous felony, and the lesser-included offense of attempted second degree murder for shooting Devin.
The trial court imposed consecutive sentences (11 years for attempted second degree murder consecutive to a 10-year aggravated robbery sentence), producing an effective 27-year sentence; Woods appealed challenging sufficiency-of-the-evidence (mental state) and consecutive sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for attempted second-degree murder (knowingly)	State: evidence shows Woods intentionally fired at fleeing victims while armed and robbing them; jury could infer he knew shots could be lethal	Woods: evidence shows only reckless firing while victims fled, not that he acted knowingly to kill	Court: Affirmed — viewing evidence in State’s favor, jury could infer Woods acted knowingly when he shot Devin
Consecutive sentencing for attempted second-degree murder	State: consecutive sentences warranted due to defendant’s extensive criminal history and dangerous-offender characteristics	Woods: consecutive sentence unreasonable and greater than deserved; requested concurrent service	Court: Affirmed — trial court did not abuse discretion; record supports findings of extensive criminal activity and dangerous offender status; aggregate sentence reasonably relates to offenses

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
State v. Inlow, 52 S.W.3d 101 (Tenn. Crim. App. 2000) (elements and proof of attempted second degree murder; assessing "knowingly" intent)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse of discretion standard with presumption of reasonableness for within-range sentences)
State v. Wilkerson, 905 S.W.2d 933 (Tenn. 1995) (requirements for consecutive sentencing: protection of public and relation to severity of offenses)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (circumstantial-evidence sufficiency standard same as direct evidence)