State of Tennessee v. Kathy Bell Noble, M2015-02288-CCA-R3-CD

Kathy Bell Noble was stopped after Officer Smalley observed her drive through an intersection where, from his vantage, the southbound signal was flashing red; he believed she did not stop for the flashing red light.
Officer Smalley observed expired registration stickers (July 2012) on the vehicle plate and ran Noble’s driver status, learning her Georgia license was suspended for failure to appear.
Noble provided proof of insurance but no current registration; she admitted the registration was invalid and had previously received tickets for expired registration.
Officer Smalley arrested Noble, her car was towed, and the stop was video-recorded and played to the jury. A certified Georgia record showing license suspension was admitted at trial after Noble withdrew her admissibility objection.
Following a jury trial, Noble was convicted of driving on a suspended license, violation of the vehicle registration law, and failure to obey a traffic control device; the convictions and sentences were affirmed on appeal.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Noble)	Held
Whether evidence sufficed to prove driving with a suspended license	Officer’s computer check and Georgia driving record prove license was suspended	Record may be inaccurate; State failed to produce live testimony to prove suspension	Conviction upheld; record was admissible and Noble waived objection; evidence sufficient
Whether evidence sufficed for violation of vehicle registration law	Officer’s observation of expired plate/stickers and Noble’s admission support conviction	Noble claimed she paid/renewed registration (no proof State negated this)	Conviction upheld; statutory duty to maintain and carry valid registration met by State’s proof
Whether evidence sufficed for failure to obey a traffic-control device	Officer observed vehicle proceed through intersection when southbound signal was flashing red; circumstantial evidence supports that northbound light was also red	Officer did not personally observe the northbound signal at the moment Noble passed and did not conclusively verify light function	Conviction upheld; circumstantial evidence and officer’s experience supported juror finding of violation
Standard of review for sufficiency of evidence	Convictions should be sustained if, viewed in light most favorable to State, any rational juror could find guilt beyond reasonable doubt	N/A (framework applied by both sides)	Standard applied (Jackson standard); appellate court defers to jury credibility findings

Jackson v. Virginia, 443 U.S. 307 (constitutional standard for reviewing sufficiency of the evidence)
State v. Tuttle, 914 S.W.2d 926 (Tenn. Crim. App. 1995) (appellate deference to jury on credibility and factfinding)
State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (appellate courts may not reweigh evidence)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on appellant to demonstrate insufficiency after conviction)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (direct and circumstantial evidence are equally probative when assessing sufficiency)