State of Tennessee v. James Yates, W2020-00706-CCA-R3-CD

On January 2, 2018, a masked man robbed the Dollar Tree in Memphis; witnesses described a tall Black male with covered face and clothing details.
MPD officers located James Yates minutes later near the scene; he hurried into a nearby Tops Bar‑B‑Q and hid in the restroom.
Officers frisked and detained Yates, recovered a potato‑chip bag containing cash from the restroom trash, and found a BB gun and clothing (hat, mask, glove, jacket) nearby that matched witness descriptions.
About fifty minutes after the robbery, police conducted a show‑up at the Dollar Tree; multiple employees identified Yates by height, build, and clothing though they did not see the robber’s face.
DNA testing later showed the hat, mask, and glove contained a major contributor profile matching Yates; he was convicted of aggravated robbery and assault and sentenced to an effective 30 years.
On appeal the court affirmed denial of the suppression motion and the convictions, but remanded for entry of a judgment form for count 2.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of show‑up identifications	Show‑up was a permissible, on‑scene investigatory procedure conducted shortly after the crime and necessary to advance the investigation	Show‑up was unnecessarily suggestive: witnesses were not separated, told a suspect had been detained, and identified under spotlighting leading to unreliable IDs	Denial of suppression affirmed — show‑up was not impermissibly suggestive given timing, location, and investigatory need; jury could assess reliability
Sufficiency of evidence to convict	Combined eyewitness IDs, recovered clothing/items matching descriptions, and DNA linking Yates to mask/hat/glove proved identity beyond reasonable doubt	IDs unreliable because witnesses never saw the robber’s face and gave inconsistent preliminary‑hearing testimony	Convictions affirmed — viewed in light most favorable to State, evidence (IDs + physical and DNA evidence) was sufficient
Form of judgment for Count 2	Trial court imposed concurrent sentence for count 2; judgment form should reflect disposition	(Yates raised no persistent challenge to sentencing form on appeal)	Case remanded for entry of a uniform judgment form for count 2 to reflect the imposed sentence

Stovall v. Denno, 388 U.S. 293 (1967) (one‑to‑one identifications may be permissible in exigent circumstances)
Neil v. Biggers, 409 U.S. 188 (1972) (factors for assessing reliability of out‑of‑court identifications)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
State v. Cribbs, 967 S.W.2d 773 (Tenn. 1998) (due process limits on suggestive identifications)
Marsh v. State, 561 S.W.2d 767 (Tenn. Crim. App. 1977) (one‑to‑one lineups viewed with suspicion but show‑ups may be allowed)
State v. Thomas, 780 S.W.2d 379 (Tenn. Crim. App. 1989) (show‑up admissibility when imperative circumstances exist)
State v. Odom, 928 S.W.2d 18 (Tenn. 1996) (standard of review for suppression findings)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (deference to jury credibility determinations)
Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (jury and trial court as primary assessors of witness credibility)