State of Tennessee v. Jimmy Williams, 558 S.W.3d 633

Victim assaulted July 27, 2008; defendant arrested but charges not pursued until 2014; indictment returned Aug. 26, 2014; trial Feb. 2-5, 2016.
Jury acquitted defendant of aggravated rape but convicted him of aggravated assault (lesser included offense).
The State filed its notice of intent to seek enhanced punishment in this case after jury deliberations had begun (filed Feb. 4, 2016 at 1:45 p.m.).
The trial court nonetheless sentenced Williams as a career offender (15 years), relying on a timely enhancement notice filed in a separate, earlier case (Indictment No. 12-06403) and on the court’s prior statements about his classification.
Court of Criminal Appeals affirmed conviction and sentence; Tennessee Supreme Court granted review to decide whether notice filed in one case gives fair notice for enhancement in a separate case.
Supreme Court held evidence was sufficient to support conviction but that statutory notice must be filed in each case; remanded to reduce sentence to six years as a Range I standard offender.

Issue	State's Argument	Williams' Argument	Held
Sufficiency of evidence for aggravated assault	Physical injuries, witnesses, and DNA corroborate victim; jury credibility determinations control	Only victim’s testimony was reliable; jury’s verdict on rape vs. assault inconsistent	Evidence sufficient to sustain aggravated assault conviction
Whether a notice filed in a different, unrelated case satisfies Tenn. Code § 40-35-202(a)	Prior timely notice in a separate case plus defendant’s knowledge and court statements gave fair/constructive notice; defendant not prejudiced	No timely, case-specific pretrial notice was filed here; statute requires notice in each case so defendant is entitled to Range I sentence	Notice must be filed in each case; post-trial/late notice in this case ineffective; defendant resentenced as Range I, sentence reduced to six years

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence review)
State v. Livingston, 197 S.W.3d 710 (Tenn. 2006) (elements of statutory notice requirement)
State v. Adams, 788 S.W.2d 557 (Tenn. 1990) (purpose of enhancement notice: fair notice and plea/trial strategy)
State v. Carter, 121 S.W.3d 579 (Tenn. 2003) (new notice required for superseding/changed charges)
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010) (post-trial notice ineffective)
State v. Patterson, 538 S.W.3d 431 (Tenn. 2017) (substantial compliance and prejudice analysis for defective notices)
State v. Stephenson, 752 S.W.2d 80 (Tenn. 1988) (continuance required to preserve objection when notice filed up to trial)
State v. Debro, 787 S.W.2d 932 (Tenn. Crim. App. 1989) (companion-case notice considered where a timely notice existed in at least one case)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate courts may modify sentences when record permits)