State of Tennessee v. Harold Allen Vaughn
W2016-00131-CCA-R3-CD
| Tenn. Crim. App. | Dec 6, 2016Background
- On Nov. 24, 2014, victim Christopher Tompkins accepted a ride from Harold Vaughn, James Martin, and Bethany Long; Vaughn ultimately drove and carried a gun. After stopping on a rural unlit road, Vaughn held Tompkins at gunpoint, Tompkins was robbed of wallet/phone/items, and Vaughn shot Tompkins five times; Tompkins suffered permanent scarring and impaired use of his right arm.
- Vaughn, Martin, and Long were indicted for attempted first-degree murder, aggravated assault, especially aggravated kidnapping, and especially aggravated robbery; the trial court severed Vaughn’s case from his co-defendants and later dismissed the kidnapping charge.
- At trial Tompkins, Long, and Martin testified; Tompkins positively identified Vaughn as the shooter; Martin testified he participated under duress after Vaughn brandished a gun.
- The jury convicted Vaughn of attempted first-degree murder (resulting in serious bodily injury), aggravated assault, and especially aggravated robbery; the trial court merged aggravated assault into the attempted-murder conviction and imposed an effective 25-year sentence.
- Vaughn appealed, arguing (1) insufficient evidence (identity, serious bodily injury, fear element, and timing for especially aggravated robbery) and (2) the trial court should have declared Martin an accomplice as a matter of law.
- The Court of Criminal Appeals affirmed convictions, held the evidence sufficient on all counts, affirmed that Martin’s accomplice status was a jury question, but remanded for corrected judgment forms reflecting the merger.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Vaughn) | Held |
|---|---|---|---|
| Identity of perpetrator | Witnesses (Tompkins, surveillance, car ID) positively identified Vaughn as shooter | Martin, not Vaughn, may have fired; witnesses had used marijuana/alcohol so ID unreliable | Sufficient evidence supports Vaughn’s identity; Tompkins’s positive ID allowed conviction |
| Serious bodily injury for attempted 1st-degree murder (affects 85% release eligibility) | Tompkins suffered extreme pain, permanent scarring, and substantial impairment of his right arm | No medical proof; short hospital stay; injuries not life‑threatening so not "serious bodily injury" | Evidence (victim testimony re pain, scarring, impairment) sufficient for juror to find serious bodily injury |
| Especially aggravated robbery — timing of injury | Serious bodily injury can be contemporaneous with or subsequent to taking property; thus especially aggravated robbery applies | Robbery completed when property taken; shooting occurred after, so cannot be "especially" aggravated | Court held serious bodily injury occurred subsequent to/in connection with robbery; conviction remains especially aggravated robbery |
| Accomplice instruction re: James Martin | Trial court should submit accomplice status to jury when disputed; corroboration requirement applies if jury finds accomplice | Trial court should have declared Martin an accomplice as a matter of law, requiring corroboration of his testimony | Trial court correctly left Martin’s accomplice status to the jury because his participation was disputed; no error |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- State v. Cribbs, 967 S.W.2d 773 (Tenn. 1998) (identity is essential element; merger of alternative convictions guidance)
- State v. Strickland, 885 S.W.2d 85 (Tenn. Crim. App. 1993) (a single identification witness’s credible testimony can support a conviction)
- State v. Griffis, 964 S.W.2d 577 (Tenn. Crim. App. 1997) (definition of accomplice and when court vs. jury determines accomplice status)
- State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (premeditation may be inferred from circumstances; factors supporting premeditation)