State of Tennessee v. Jacob Scott Hughes, M2016-01222-CCA-R3-CD

Background

Defendant Jacob Scott Hughes was convicted of first-degree felony murder and aggravated child abuse for the fatal beating of his girlfriend’s 16‑month‑old daughter; sentences: life + 25 years, consecutive.
Medical testimony (pediatric specialists and forensic pathologist) showed multiple blunt‑force injuries, skull fracture, diffuse brain injury with subdural hematomas, extensive retinal hemorrhages, ~35 external injuries, and evidence inconsistent with a bathtub fall or CPR; cause of death: beaten to death.
Witnesses and first responders described the child as lifeless with multiple bruises; Defendant gave varying accounts (bathtub fall, left to get bleach) and sent contemporaneous Facebook messages and photos showing the child’s injuries and black stools.
Defendant and the child’s mother, Neena Costanza, were both initially indicted; Costanza later pled guilty to lesser‑included offenses. The trial court limited how the mother could be referenced (by name, not as "co‑defendant").
At trial, the court admitted selected autopsy photographs (some cropped/redacted) and Facebook messages; the court denied a motion to redact a Facebook reference to "Hammer Skin." Defendant challenged these evidentiary rulings on appeal.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hughes)	Held
Trial court prevented calling the victim’s mother "co‑defendant" and barred mention of her guilty plea	Limiting the label avoided confusing or unfairly prejudicing the jury; Defendant could still argue the mother was the "true culprit"	Court erred by restricting reference to Costanza as "co‑defendant" and by excluding plea information	Affirmed — trial court acted within discretion; defendant could argue blame to mother but not identify her as "co‑defendant" or rely on plea as relevant evidence
Admission of Facebook message referencing "Hammer Skin" (racial/gang connotation)	Any reference was at most ambiguous; even if tied to a racist group, admission was harmless given overwhelming evidence of guilt	Reference should have been excluded under prior limine ruling; admission was prejudicial because it suggested gang affiliation/racial animus	Affirmed — no reversible error; ambiguity of the reference and overwhelming proof made any error harmless beyond a reasonable doubt
Admission of autopsy photographs, including cropped image of vaginal area post‑incision	Photographs were relevant to refute defense theory (bathtub fall), showed injuries not visible externally, and were properly cropped to reduce prejudice	Certain autopsy photos were gruesome and inflammatory; admission unfairly prejudiced the jury	Affirmed — trial court conducted individualized balancing under Rules 401/403, admitted photos with probative value and excluded/edited overly inflammatory images; no abuse of discretion

Key Cases Cited

State v. Pylant, 263 S.W.3d 854 (Tenn. 2008) (standard for admissibility and appellate review of evidentiary rulings)
State v. Powers, 101 S.W.3d 383 (Tenn. 2003) (Rule 403 balancing for probative value versus unfair prejudice)
State v. Banks, 564 S.W.2d 947 (Tenn. 1978) (principles for admission of gruesome photographs and limits on inflammatory evidence)
State v. Faulkner, 154 S.W.3d 48 (Tenn. 2005) (trial court discretion in admitting photographic evidence)
State v. Willis, 496 S.W.3d 653 (Tenn. 2016) (factors for evaluating gruesome autopsy/scene photographs and probative value)
Lafferty v. State, 749 P.2d 1239 (Utah 1988) (factors for balancing admissibility of photographic evidence)