State of Tennessee v. Floyd Antonius Taylor, W2020-00103-CCA-R3-CD

Tipton County indicted Floyd Antonius Taylor on two counts of delivery of a Schedule II controlled substance (≥ 0.5 g); counts severed and only Count 2 (allegedly in a drug-free zone) proceeded to jury trial.
Covington police used confidential informant (CI) Patrick Daugherty for a controlled buy on August 17, 2016; CI was searched and given $100 and two body cameras; text messages from a phone number tied to Taylor arranged the meeting at a high school track.
Video and stills (date stamp incorrect) show a hand-to-hand exchange in the track/parking area ~110 feet from the school building; officers recovered .72 grams of cocaine from the CI and submitted it to TBI for testing.
Defense objected to portions of recorded conversation as prior bad-act evidence (motion in limine); trial court allowed the video (with agreement defendant would not send video to jury room); transcripts of the motion hearing and new-trial hearing are not in the appellate record.
Jury convicted Taylor; trial court sentenced him to 15 years, dismissed Count 1; Taylor appealed, arguing improper 404(b) evidence and insufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of appeal	State: notice untimely filed beyond 30 days	Taylor: late filing attributable to clerk date discrepancy	Court waived timeliness defect in interest of justice
Admission of prior-bad-act evidence (Rule 404(b)) and testimony about absconding	State: evidence admissible / trial court acted within discretion	Taylor: prior-act statements and reference to absconding were inadmissible and prejudicial	Appellate review precluded by missing transcripts; presumption that trial court rulings were correct; no relief granted
Sufficiency of the evidence (delivery within drug-free zone; identity)	State: video, texts, CI testimony, officer ID, and chemical analysis prove delivery and location beyond reasonable doubt	Taylor: video equipment/date stamp faulty and officers lacked 100% visual accountability; CI credibility questioned	Viewing evidence in light most favorable to State, rational juror could find guilt beyond reasonable doubt; conviction affirmed

Jackson v. Virginia, 443 U.S. 307 (established standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Evans, 838 S.W.2d 185 (Tenn. 1992) (presumption of guilt after jury verdict; burden on defendant on appeal)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (appellate burden to show insufficiency)
State v. Elkins, 102 S.W.3d 578 (Tenn. 2003) (appellate review entitled to strongest legitimate view of evidence)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same sufficiency standard for direct and circumstantial evidence)
State v. Troutman, 979 S.W.2d 271 (Tenn. 1998) (appellant’s duty to include necessary transcripts; failure waives review)
State v. Ballard, 855 S.W.2d 557 (Tenn. 1993) (absence of transcript precludes appellate review)
State v. Oody, 823 S.W.2d 554 (Tenn. Crim. App. 1991) (trial court ruling presumed correct where record inadequate)
State v. Pruett, 788 S.W.2d 559 (Tenn. 1990) (credibility and weight of evidence are for the jury)