State of Tennessee v. Kaylecia Woodard
E2016-00676-CCA-R3-CD
| Tenn. Crim. App. | Jun 15, 2017Background
- On June 16, 2014, Anthony Smith robbed a convenience store at gunpoint; Kaylecia Woodard was charged as an accomplice (allegedly planned the robbery, drove the getaway car, and provided the handgun).
- Two accomplices, Smith and Timeya Harris, testified at trial describing Woodard’s role; both pleaded guilty to aggravated robbery.
- Police stopped Woodard’s car shortly after the robbery; officers found a backpack in the trunk containing a .22 revolver identified by Smith and personal items linking the bag to Woodard.
- Evidence of Woodard’s alleged gang membership (127 Athens Park Bloods) included testimony from Harris, text messages, Facebook photos/hand signs, and a Gang Intelligence Unit confirmation.
- The jury convicted Woodard of aggravated robbery and found her a criminal gang member; the trial court enhanced her sentence under Tenn. Code Ann. § 40-35-121, imposing 15 years (Class A felony range).
- On appeal, Woodard challenged (1) sufficiency of the evidence (including lack of corroboration for accomplice testimony) and (2) constitutionality of the gang-enhancement statute; the court affirmed the conviction but held the gang-enhancement unconstitutional and remanded for resentencing as a Class B felony.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Woodard) | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated robbery | Accomplice testimony corroborated by vehicle stop, weapon in defendant’s backpack, suspicious witness description | Accomplices’ testimony was uncorroborated and therefore insufficient | Conviction affirmed; corroboration (witness description + weapon in defendant’s bag + presence driving vehicle) sufficiently connected Woodard to the crime |
| Sufficiency of evidence for gang-membership finding | Testimony, text messages, Facebook photos/hand signs, and Gang Unit confirmation corroborated accomplice testimony | Insufficient corroboration of accomplice testimony to prove gang membership | Jury finding of gang membership upheld on the available corroborating evidence |
| Facial vagueness/overbreadth of Tenn. Code Ann. § 40-35-121(a)(2)(D),(G) (First Amendment) | Statute narrows definition of gang member; challenges waived if not raised pretrial | Statute is overbroad/vague and chills protected expression (nicknames, clothing, hand signs) | Court treated challenge as timely (facial attack) and relied on prior precedent concluding the sentencing enhancement portions are unconstitutional |
| Validity of § 40-35-121(b) (gang enhancement nexus to legislative purpose/due process) | Enhancement is an element that may be submitted to jury; statute valid as written | Enhancement lacks sufficient nexus and is unconstitutional as applied and facially | Court concluded (following State v. Bonds precedent) that § 40-35-121(b) (and related enhancement provisions) is facially unconstitutional; vacated gang enhancement and remanded for resentencing as Class B felony |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency of evidence review)
- State v. Bonds, 502 S.W.3d 118 (Tenn. Crim. App. 2016) (held gang-enhancement provision unconstitutional for lack of nexus)
- State v. Bigbee, 885 S.W.2d 797 (Tenn. 1994) (accomplice corroboration rule and elements of corroboration)
- State v. Bane, 57 S.W.3d 411 (Tenn. 2001) (accomplice testimony cannot alone support conviction)
- Alleyne v. United States, 133 S. Ct. 2151 (U.S. 2013) (fact increasing prescribed punishment must be submitted to jury)
- State v. Dixon, 530 S.W.2d 73 (Tenn. 1975) (an unconstitutional statute is void ab initio and cannot support a conviction)