State of Tennessee v. Javonta Marquis Perkins, M2015-02423-CCA-R3-CD

On March 3, 2012, victim Maurice Hegwood was robbed at gunpoint in his parents’ driveway; two men stole his 2009 Pontiac G6 and fled. The incident lasted ~10–15 minutes in well-lit conditions.
Police located the wrecked vehicle after a brief pursuit; two suspects (Perkins and co-defendant Quentin McClain) were apprehended nearby and taken to a hospital.
Hegwood viewed a person in a hospital room about two hours after the robbery and identified Perkins as the gunman; police testimony varied about whether officers directed Hegwood to the room.
Perkins was indicted for aggravated robbery, carjacking, and weapon possession; a jury convicted him on all counts. Trial court imposed concurrent 10-year sentences for aggravated robbery and carjacking and a consecutive six-year sentence for the weapon count (effective 16 years).
Perkins appealed, arguing (1) the hospital identification should have been suppressed, (2) the court improperly instructed criminal responsibility, (3) evidence was insufficient, and (4) his sentences were excessive.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Perkins)	Held
Suppression of pretrial ID	ID reliable; spontaneous hospital viewing, not police suggestion	Hospital "show-up" was unduly suggestive and unreliable	Denied suppression; court found viewing not product of police suggestion and Biggers reliability factors supported admission
Criminal-responsibility jury instruction	Instruction permissible; evidence supported alternative liability theory	Instruction not fairly raised by evidence and prejudicial	Instruction proper; evidence fairly raised criminal-responsibility theory (both actors participated)
Sufficiency of the evidence	Identity and elements proven by victim testimony, descriptions, chase, and arrest near wreck	Identification was tainted by suggestive show-up; thus proof of identity insufficient	Evidence sufficient; jury credited victim ID and other corroborating proof
Sentence length/variation	Sentence within statutory range and supported by enhancement factors	Sentence excessive given Perkins was 16 at offense and disparity with 14‑year‑old co-defendant	No abuse of discretion; court applied enhancement factors and reasonably declined mitigation for youth

Neil v. Biggers, 409 U.S. 188 (1972) (two‑part test for due process challenge to pretrial identification)
Stovall v. Denno, 388 U.S. 293 (1967) (totality of circumstances governs suggestive identification challenges)
Manson v. Brathwaite, 432 U.S. 98 (1977) (reliability factors for suggestive identifications)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse of discretion review with presumption of reasonableness for within‑range sentences)
State v. Faulkner, 154 S.W.3d 48 (Tenn. 2005) (jury instruction preservation and review rules)
State v. Hodges, 944 S.W.2d 346 (Tenn. 1997) (jury charge must fairly submit issues and not mislead jury)