State of Tennessee v. Jamichael Polk Armstrong, M2015-02083-CCA-R3-CD

CI working with Columbia PD conducted a controlled purchase of crack cocaine at Michael/“Al” Harding’s home on June 17, 2011; CI handed money to a man later identified as Jamichael Polk Armstrong, who allegedly handed back drugs.
Officers equipped CI with a hidden camera and listening device, followed CI to and from the purchase, and recovered 0.9 grams of cocaine base from the CI after the transaction.
Still photos/video from the hidden camera and CI testimony were used to identify Armstrong; Officer Dark also identified Armstrong from the video.
Armstrong was indicted for sale of cocaine >0.5 g within 1,000 feet of a school; jury convicted him of the lesser-included offense of facilitation of sale within a drug-free school zone.
Trial court sentenced Armstrong to 10 years (Range I), and applied the Drug-Free School Zone Act enhancement, requiring service of first 8 years at 100% release eligibility.
On appeal, Armstrong challenged (1) sufficiency of the evidence and (2) application of the Act to a facilitation conviction; the State conceded the sentencing issue but defended sufficiency.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Armstrong)	Held
Sufficiency of evidence to support facilitation conviction	Video, CI testimony, officer ID and recovered 0.9 g support a reasonable juror finding Armstrong furnished substantial assistance	Conviction rests on an unreliable CI who had credibility issues and the video does not conclusively show Armstrong sold the drugs	Conviction affirmed — viewed in light most favorable to State, jury could find facilitation proven beyond a reasonable doubt
Application of Drug-Free School Zone Act to facilitation conviction	(State ultimately conceded error on appeal)	Act was applied to enhance classification to Class B and impose 100% service; defendant argued Act does not apply to facilitation	Remanded for resentencing: Act does not apply to facilitation (per controlling Tennessee Supreme Court precedent), conviction reclassified as Class C and sentence adjusted to the appropriate range and 30% service

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (sufficiency review same for direct and circumstantial evidence; appellate court must not reweigh evidence)
State v. Davis, 354 S.W.3d 718 (Tenn. 2011) (appellate review takes strongest legitimate view of the evidence and all reasonable inferences)
State v. Hanson, 279 S.W.3d 265 (Tenn. 2009) (defendant bears burden on appeal to show evidence legally insufficient to sustain verdict)