State of Tennessee v. George A. Belt, M2016-00663-CCA-R3-CD

Defendant George A. Belt (stepfather) was convicted by a Bedford County jury of two counts of rape (merged to one), one count of incest, and one count of purchasing alcohol for a minor; effective sentence 20 years concurrent.
Victim, the defendant’s 14‑year‑old stepdaughter, testified defendant bought her alcohol, she became intoxicated, and later awoke to the defendant performing oral sex, digital contact, and partial penile penetration.
Forensic exam showed no anogenital injury; PA testified absence of injury does not preclude penetration and injury is uncommon.
Defendant initially denied sexual contact but admitted in TBI interviews (and a written statement) that his penis briefly entered the victim’s vagina; trial testimony denied rape and claimed coercion into confessing.
Jury convicted; at sentencing trial court applied multiple enhancement factors (prior convictions, abuse of position of trust, offense to gratify sexual desire, failure to comply with release) and imposed within‑range sentences.

Issue	State's Argument	Belt's Argument	Held
Sufficiency of evidence for rape and incest	Victim's credible testimony plus defendant’s admissions suffice	Victim’s testimony alone insufficient; lack of medical corroboration and defendant’s denial create reasonable doubt	Convictions affirmed; evidence (victim testimony + defendant admissions) sufficient under Jackson standard
Weight of forensic evidence	Lack of injury does not negate sexual contact; expert explained normal findings are common	Lack of physical injury supports defendant’s denial	Court accepted expert explanation; lack of injury not dispositive
Credibility conflict (victim vs defendant)	Jury entitled to resolve credibility; victim found credible	Defendant argues jury should credit his trial denial	Appellate court defers to jury credibility determinations
Sentence excessiveness	Sentences within statutory range and supported by enhancement factors and victim impact	Sentence ‘‘does not fit the crime’’ (conclusory)	Sentences affirmed as within range and not an abuse of discretion

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of evidence review)
Bolin v. State, 405 S.W.2d 768 (trial judge and jury are primary fact‑finders for credibility)
Grace v. State, 493 S.W.2d 474 (jury verdict accredits state witnesses and resolves conflicts)
Tuggle v. State, 639 S.W.2d 913 (burden on appellant to show insufficiency after conviction)
State v. Bise, 380 S.W.3d 682 (standard of review for within‑range sentencing; presumption of reasonableness)
State v. Flake, 88 S.W.3d 540 (credibility and weight are jury province)
State v. Holder, 15 S.W.3d 905 (same)
State v. Pappas, 754 S.W.2d 620 (fact issues resolved by trier of fact)
State v. Evans, 838 S.W.2d 185 (appellate sufficiency review principles)
State v. Anderson, 835 S.W.2d 600 (appellate sufficiency review)