State of Tennessee v. Jereme Dannuel Little, 2013 Tenn. LEXIS 309

Defendant Little was tried in a consolidated proceeding for two aggravated robberies and one especially aggravated kidnapping; a judgment of acquittal was granted on the robbery counts, leaving the kidnapping count for the jury.
Grayson, an accomplice in the 1998 robbery, testified against Little and claimed the kidnapping involved torture and dog feces; other witnesses contradicted or corroborated parts of the tale.
The State argued the 1998 robbery evidence showed motive for the kidnapping; defense sought to limit or strike references after acquittal on the robbery charges.
The trial court instructed the jury to disregard the dismissed robbery counts and allowed the State to reference the robbery as motive; defense counsel objected to any such reference.
The jury found Little guilty only of especially aggravated kidnapping and the court imposed an eighteen-year sentence.
On appeal, the Court of Criminal Appeals affirmed; the issue before the Tennessee Supreme Court was whether the trial court erred by not informing the jury of the acquittals and related evidentiary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must the jury be informed of partial acquittals in a multi-charge trial?	Holman rule should apply; acquittals foreclose use of prior-crime evidence.	Rhode Island approach should apply; acquittals may be used if properly disclosed to jurors.	No reversible error; informing jury not required beyond removal notice.
Did the trial court err by not giving a Rule 404(b) limiting instruction after acquittal on the robbery charges?	Accomplice evidence requires limiting instructions to prevent prejudice.	No specific limiting instruction requested; error not preserved.	Not reversible; defendant failed to request/raise error timely.
Was the acquittal of the robbery charges improperly used to establish accomplice corroboration for the kidnapping?	Accomplice corroboration requirement should apply to motive evidence.	Grayson’s testimony as victim does not require corroboration; motive evidence allowed.	Corroboration not required for Grayson’s kidnapping testimony; no error.
Was the jury correctly instructed on criminal responsibility for conduct of another?	Instruction properly covered aiding and abetting and liability for others’ acts.	Instruction could mislead or distort liability.	Court did not err; instruction appropriate.
Were cumulative-error concerns meritorious?	Combined errors violated fair trial standards.	No individual errors; no cumulative prejudice.	No reversible cumulative error.

State v. Holman, 611 S.W.2d 411 (Tenn. 1981) (Holman rule on prior-crime evidence in subsequent trials)
State v. Turner, 352 S.W.3d 425 (Tenn. 2011) (acquittals of others deemed irrelevant to defendant’s guilt)
State v. James, 315 S.W.3d 440 (Tenn. 2010) (standard for judgment of acquittal; sufficiency after State rests)
State v. Odom, 336 S.W.3d 541 (Tenn. 2011) (presumption jurors follow trial court’s instructions)
State v. Gilliland, 22 S.W.3d 266 (Tenn. 2000) (contextual background for 404(b) evidence)
State v. Howell, 868 S.W.2d 238 (Tenn. 1993) (importance of limiting instructions to prevent prejudice)
State v. Shropshire, 45 S.W.3d 64 (Tenn. Crim. App. 2000) (Holman rule discussed in modern context)
Conner v. State, 531 S.W.2d 119 (Tenn. Crim. App. 1975) (accomplice corroboration standard)