State of Tennessee v. David Leo Pipes, W2015-02073-CCA-R3-CD

Defendant David Leo Pipes was tried for theft of property valued at $1,000–$10,000 (diamond ring); a jury convicted him.
Victim Cheryl Hight left a diamond ring in a jewelry dish in her master bathroom; defendant worked in that bathroom installing blinds the morning the ring went missing.
Surveillance from a pawn shop showed Pipes attempting to pawn one or more rings the same day; pawn employee identified a ring later returned to the victim as one of those attempted to be pawned.
Officer Graves recovered the ring taped to the victim’s door a few days later; the victim and the pawnbroker identified it as the missing ring.
Defendant admitted being in the bathroom but denied taking the ring; he presented no evidence at trial.
At sentencing, the trial court classified Pipes as a Range II, multiple offender based on two prior felony convictions and imposed a six-year sentence with 35% release eligibility; the Court of Criminal Appeals affirmed.

Issue	State's Argument	Pipes' Argument	Held
Sufficiency of the evidence to support theft conviction	Circumstantial and direct evidence (presence in bathroom, pawn attempt, identification of recovered ring) supports guilt	Evidence did not prove identity of the stolen ring or that Pipes possessed it (surveillance didn’t show items; pawn employee uncertain)	Affirmed — evidence sufficient for a rational jury to find guilt beyond a reasonable doubt
Proper range and use of prior convictions for classification	Two prior Class E felonies justified Range II classification	Prior felonies should determine alternative-sentencing eligibility but not Range II classification	Affirmed — two prior felonies made Range II proper
Excessiveness of sentence / denial of alternative sentencing	Prior criminal history and failure of rehabilitation justified within-range sentence and denial of alternatives	Sentence excessive; court failed to adequately apply sentencing principles	Affirmed — six years (within-range) and denial of alternative sentencing not an abuse of discretion
Trial court’s articulation of sentencing reasons	Court cited prior convictions, failed rehabilitation, and statutory factors	Court did not sufficiently emphasize sentencing principles	Affirmed — presumption of reasonableness applies; articulation adequate under Bise standard

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence)
State v. Dorantes, 331 S.W.3d 370 (circumstantial-evidence sufficiency standard same as direct-evidence standard)
State v. Bise, 380 S.W.3d 682 (presumption of reasonableness for within-range sentences and articulation standard)
State v. Grace, 493 S.W.2d 474 (jury verdict accredits State's witnesses)
State v. Robinson, 400 S.W.3d 529 (discusses actual vs. constructive possession)
State v. Williams, 920 S.W.2d 247 (sentencing procedure guidance)
State v. Carter, 254 S.W.3d 335 (no presumptive minimum sentence; court may impose any within-range sentence consistent with Sentencing Act)