State of Tennessee v. Deangelo Norton, W2016-02069-CCA-R3-CD

Victim (7) alleged repeated sexual abuse by his uncle, Deangelo Norton, in 2011–2012 (fellatio and anal penetration).
Victim disclosed to mother in August 2012; mother sought medical evaluation (no physical findings) and reported to DCS/police.
Forensic interview and medical evaluations in Oct. 2012 recorded consistent allegations; experts explained lack of physical findings does not preclude abuse.
Norton was indicted on rape of a child and aggravated sexual battery; he sought to introduce evidence of the victim’s prior "hunching" behavior at a 2009 children’s party under Tenn. R. Evid. 412.
Trial court excluded the proffered prior-conduct testimony as irrelevant under Rule 412 and convicted Norton on both counts; convictions merged and Norton received 25 years at 100%.

Issue	State's Argument	Norton's Argument	Held
Admissibility of evidence of the victim’s prior "hunching" (knowledge of sexual matters) under Tenn. R. Evid. 412	Evidence inadmissible: witnesses didn’t see victim engage in the conduct, and proffered conduct was not shown to resemble the alleged acts or explain knowledge	Proffered testimony showed victim’s prior sexual behavior/knowledge and was therefore admissible under Rule 412(c)(4) to show knowledge of sexual matters	Court affirmed exclusion: testimony irrelevant and insufficiently connected to victim or charged acts; no abuse of discretion in excluding it
Sufficiency of evidence for rape of a child (anal intercourse and fellatio)	Victim’s consistent testimony and reports suffice; medical absence of trauma does not negate proof	Argued victim’s uncorroborated testimony insufficient and inconsistent	Court held evidence sufficient: child’s uncorroborated but consistent testimony can support conviction; jury credibility finding upheld
Sufficiency of evidence for aggravated sexual battery (sexual contact with victim under 13)	Victim’s testimony established unlawful sexual contact; identity and age proven	Denied acts occurred; challenged sufficiency	Court held evidence sufficient for aggravated sexual battery for same reasons as rape conviction

State v. Sheline, 955 S.W.2d 42 (Tenn. 1997) (review of Rule 412 rulings is for abuse of discretion)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for appellate review of sufficiency of the evidence)
State v. Elkins, 102 S.W.3d 578 (Tenn. 2003) (child victim’s uncorroborated testimony can support conviction)
State v. Radley, 29 S.W.3d 532 (Tenn. Crim. App. 1999) (verdict upheld unless inconsistencies create reasonable doubt)
Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (jury and trial court as primary factfinders; appellate courts defer on credibility)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on appeal to show insufficiency after jury conviction)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same standard for circumstantial and direct evidence sufficiency)
State v. Smith, 42 S.W.3d 101 (Tenn. Crim. App. 2000) (lack of physical corroboration does not preclude conviction for sexual offenses)