State of Tennessee v. Henry Lee Jones, 450 S.W.3d 866

Two elderly Bartlett victims were murdered August 23, 2003; Jones was indicted for two counts of first-degree murder and later death sentences were imposed; Rule 404(b) hearing admitted evidence of Perez murder to prove identity; trial court found similarities but differed on prejudice; Perez murder evidence was presented at trial with extensive testimony and photos; Jones appealed arguing improper 404(b) admission and sufficiency; Supreme Court reversed due to prejudicial error and remanded for new trial with potential death penalty on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Jones	Jones	Evidence sufficient to support each conviction (with corroboration of cooperator)
admissibility of Perez murder under Rule 404(b) as a signature crime	Perez murder highly similar to James murders as a signature crime	No highly distinctive MO; not a signature crime; risk of unfair prejudice high	Trial court abused discretion; Perez murder not a signature crime; its admission prejudicial and reversible
Harmless error analysis	Error in admitting 404(b) evidence prejudiced the verdict		Erroneous admission affected the verdict; new trial warranted
Contextual background admissibility under Rule 404(b)	Evidence may be used to provide context	Only if probative and not prejudicial	Contextual background allowed with careful limiting; require safeguards on admissibility

Dorantes v. State, 331 S.W.3d 370 (Tenn. 2011) (governs sufficiency review and standard of review)
Bane v. State, 57 S.W.3d 411 (Tenn. 2001) (corroboration standard for accomplice testimony)
Parton v. State, 694 S.W.2d 299 (Tenn. 1985) (clear and convincing standard in 404(b))
DuBose v. State, 953 S.W.2d 649 (Tenn. 1997) (abuse of discretion standard for 404(b) rulings)
Dotson v. State, 254 S.W.3d 378 (Tenn. 2008) (restrictive Rule 404(b) balancing for unfair prejudice)