State of Tennessee v. Juan Cerano, W2015-02234-CCA-R3-CD

Defendant Juan Cerano was indicted for rape of a child and aggravated sexual battery based on alleged anal penetration of a 13‑year‑old in June 2013; jury convicted on both counts, court merged convictions and imposed a 30‑year sentence.
Victim reported the assault the day after the incident; medical exam within five days showed a perianal laceration consistent with penetrating trauma; clinicians testified injuries were consistent with sexual assault.
Defense sought production of Department of Children’s Services (DCS) records concerning prior allegations involving the victim for in camera inspection and admission; trial court denied production after in camera review (no transcript or written order appears in record).
At trial defense impeached the victim with limited testimony that the victim told a DCS worker his mother wanted him to lie; defense argued the full DCS and medical records were necessary to present his defense.
Trial court excluded broader DCS/medical records as irrelevant (and to prevent collateral impeachment of non‑testifying witnesses); defense renewed request post‑State case; court again limited evidence.
On appeal defendant argued denial of full DCS records deprived him of his right to present a defense; appellate court affirmed, primarily because the record lacked the DCS files and the trial court’s ruling transcript/order, preventing meaningful review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of production/admission of DCS records violated right to present a defense	State: Record is insufficient to review; trial court’s evidentiary rulings presumptively correct	Cerano: Full DCS records were critical to impeach victim and show motive to fabricate; exclusion thwarted defense	Affirmed — appellate record lacked the DCS records and ruling transcript/order, so court presumed correctness and declined to find reversible error
Whether excluded evidence was critical, reliable, and outweighed exclusionary interests under Brown test	State: No adequate record to apply Brown; interests in evidentiary rules and relevance justified exclusion	Cerano: Records bore on credibility and prior untruthful allegations, meeting Brown factors	Court did not reach a merits Brown balancing because the missing record prevented review; defendant failed to carry burden to demonstrate error

Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (constitutional right to present a defense limited by evidentiary rules that are not arbitrary)
United States v. Scheffer, 523 U.S. 303 (U.S. 1998) (rulemakers have latitude to exclude evidence under evidentiary rules)
State v. Flood, 219 S.W.3d 307 (Tenn. 2007) (rules of evidence may be applied without violating right to present a defense if not arbitrary)
State v. Brown, 29 S.W.3d 427 (Tenn. 2000) (three‑part test for determining if exclusion of evidence violates constitutional right to present a defense)
State v. Ballard, 855 S.W.2d 557 (Tenn. 1993) (appellant bears burden to prepare sufficient record for appellate review)
State v. Richardson, 875 S.W.2d 671 (Tenn. Crim. App. 1993) (presumption of correctness where record is inadequate to review ruling)