State of Tennessee v. Jerica Elizabeth Taylor, M2016-02578-CCA-R3-CD

Background

On December 14, 2014, William Majano (victim) was robbed in his truck after responding to a text from the defendant, Jerica Elizabeth Taylor; two men approached, one pointed a gun and removed items, and the victim’s debit card, cell phone, and GPS were taken.
The victim identified Taylor from a photograph on the phone left behind and in subsequent photo lineups and at trial; police later recovered the victim’s debit card at a nearby townhome where Taylor and others were located.
Taylor was indicted and tried with co-defendants; a jury convicted her of aggravated robbery (Tenn. Code Ann. § 39-13-402). The trial court sentenced her as a Range I offender to 11 years at 85% service.
On appeal Taylor challenged (1) sufficiency of the evidence, (2) limitations on cross-examination of the victim (prior patronizing-prostitution conduct, immigration status, and Taylor’s juvenile age), (3) admissibility of the photo lineup, and (4) sentencing (officer testimony about juvenile adjudication and sentence length).
The Court of Criminal Appeals affirmed: evidence supported criminal responsibility as a principal, the trial court did not abuse discretion in evidentiary rulings, the record was inadequate to sustain the lineup claim, and sentencing was within-range and properly supported.

Issues

Issue	State's Argument	Taylor's Argument	Held
Sufficiency of evidence	Victim ID, phone metadata, texts, card recovered at townhome, and actions showing Taylor initiated and assisted robbery	No proof Taylor possessed a weapon, knew a gun would be used, or coordinated with co-defendants	Conviction affirmed — circumstantial and direct evidence suffice to show she was a principal actor
Limits on cross-examination — victim’s patronizing prostitution	Exclusion proper under Rules 404/608/609; misdemeanor or dismissed, low probative value	Should impeach victim’s credibility and explain flight/avoidance of police	Court did not err — prior sexual conduct and dismissed/ misdemeanor citation not admissible for impeachment
Limits on cross-examination — victim’s immigration status	Immigration status irrelevant to credibility; more prejudicial than probative	Relevant to credibility because it could explain flight/reluctance to speak to police	Exclusion upheld — no evidence victim’s status affected testimony or bank representations; irrelevant under Rules 401/403
Limits on cross-examination — defendant’s juvenile age	Age evidence would be unduly prejudicial and not sufficiently probative; no adequate proffer/transcript	Victim’s knowledge of her minority would impeach his credibility and motive to blame her	Exclusion upheld — minimal probative value, high risk of prejudice; trial court acted within discretion
Admissibility of photo lineup	Admission supported by trial court rulings; appellate record incomplete to show error	Photo was a mugshot revealing prior contact with police and unduly prejudicial under Rule 403	Not reached on merits — appellate record incomplete; presumption trial court ruling correct
Sentencing — officer testimony and length	Officer Polk’s testimony about juvenile delinquency and pending matters admissible; sentence within-range and properly enhanced	Officer testimony improperly introduced juvenile matters; sentence above presumptive minimum excessive	Affirmed — hearsay exception and sentencing statutes permit reliable evidence; court properly applied enhancement factors and did not abuse discretion

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
State v. Vasques, 221 S.W.3d 514 (Tenn. 2007) (appellate standard reviewing sufficiency)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (trial court resolves witness credibility)
State v. Sheffield, 676 S.W.2d 542 (Tenn. 1984) (appellate review limitations on reweighing evidence)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (circumstantial evidence standard same as direct)
State v. Maxwell, 441 S.W.2d 503 (Tenn. Crim. App. 1969) (principals liable when present and ready to assist)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse-of-discretion review of within-range sentences)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (sentencing considerations and factors)