State of Tennessee v. David Scott Hall, M2015-02402-CCA-R3-CD

D. Scott Hall (defendant) lived briefly with a family after flood damage; on May 18, 2010 a camera belonging to Hall was found hidden in the 13‑year‑old victim’s bedroom and contained videos that would have recorded her dressing after showering.
Two videos from the camera were admitted: a short test clip and a longer clip showing the camera placed on the dresser aimed at the area where the victim dressed; the victim discovered the camera and stopped the recording.
Hall admitted making the videos but maintained he was videotaping fish in a tank and accidentally left the camera; he later wrote an unsigned letter to the DA recounting a similar explanation.
Hall was convicted after a bench trial of attempted especially aggravated sexual exploitation of a minor (Class C felony) and sentenced to four years (one year confined, balance on supervised probation).
On appeal Hall raised multiple claims: insufficiency of the evidence, improper expert testimony about adult pornography, entitlement to coram nobis relief based on media found after trial, speedy‑trial violation, chain‑of‑custody and evidentiary objections, and prosecutorial misconduct; the Court of Criminal Appeals affirmed.

Issue	State's Argument	Hall's Argument	Held
Sufficiency of evidence for attempted especially aggravated sexual exploitation	Videos, circumstances, and conduct show Hall took substantial step to record a lascivious exhibition	No "lascivious exhibition" occurred; mere nudity insufficient	Affirmed: viewed favorably to State, evidence sufficient to support attempt conviction (relying on facts and Whited analysis)
Admissibility of Detective Gish’s testimony that adult pornography was found on seized devices	Even if error, harmless because case turned on videos	Testimony was irrelevant, prejudicial, and beyond expert scope	Error in admitting statement was found but harmless; did not affect outcome
Coram nobis — newly discovered media on returned hard drive	State: Hall was not without fault; evidence not newly discovered or outcome‑determinative	Hall: computer returned after confinement contained photos/videos of aquariums that would support his defense	Denied: not entitled because he had access/duty to secure hard drive earlier and evidence was not newly discovered in statutory sense
Speedy trial violation (4+ year delay)	Delay explained; Hall did not assert right or show prejudice	Delay violated Sixth Amendment, impaired memory and defense	Denied: Barker factors weighed against relief (length triggered inquiry, but reasons, lack of assertion, and minimal prejudice defeated claim)

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Whited v. State, 506 S.W.3d 416 (Tenn. 2016) (interpretation of "lascivious" and evaluation framework for sexual‑exploitation depictions)
Barker v. Wingo, 407 U.S. 514 (speedy trial balancing test)
Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (coram nobis procedure and standard)
Cabbage v. State, 571 S.W.2d 832 (Tenn. 1978) (appellate view of evidence and inferences)