State of Tennessee v. Lee Dewane Watts
M2015-02404-CCA-R3-CD
| Tenn. Crim. App. | Jan 19, 2017Background
- Defendant Lee Dewane Watts was convicted by a Montgomery County jury of two counts of first‑degree felony murder (merged) and one count of especially aggravated robbery for the beating and robbery of his mother; trial court sentenced him to life for murder and a consecutive 25 years for robbery.
- Victim suffered severe blunt‑force head trauma consistent with a hammer blow and died; a hammer with the victim’s blood was recovered and medical experts linked the injuries to such an object.
- Multiple witnesses placed Watts at or leaving the victim’s apartment the night and morning of the assault; several witnesses said Watts repeatedly left a drug‑use group claiming he was going to his mother’s for money and returned with cash used to buy drugs.
- DNA/forensic evidence: blood matching the victim on the hammer and blood matching Watts on a purple shirt seen on him the night before/after the assault.
- Watts gave multiple inconsistent accounts to police, then made an inculpatory admission during interview and wrote a two‑page statement confessing to hitting his mother with a hammer.
- At sentencing the court applied enhancement factors (prior convictions; victim vulnerability; offender on parole), ordered consecutive sentences (including mandatory consecutive service to a parole sentence), and denied relief on appeal.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Watts) | Held |
|---|---|---|---|
| Sufficiency of evidence for murder & robbery | Evidence (confession, hammer with victim’s blood, witnesses placing Watts at scene, DNA on shirt, motive/interest in victim’s money) supports convictions | Confession required corroboration under State v. Bishop and evidence insufficient to prove guilt beyond reasonable doubt | Affirmed: evidence (direct + circumstantial) sufficient; confession corroborated by independent proof |
| Requirement to corroborate confession (Bishop) | Corroboration satisfied by physical and testimonial evidence (hammer, DNA, witnesses, no forced entry) | Confession not independently corroborated as required | Affirmed: corroboration present via multiple independent facts and evidence |
| Consecutive sentencing / dangerous offender classification | Consecutive sentences justified (mandatory to consecutive parole term; dangerous offender findings supported by record) | Court erred in ordering consecutive sentences and labeling him dangerous given nonviolent criminal history | Affirmed: consecutive to parole mandatory; consecutive robbery sentence and dangerous‑offender rationale not an abuse of discretion |
| Maximum 25‑year robbery sentence / enhancement factors | Enhancement factors (prior convictions, victim vulnerability, on parole) support maximum within statutory range | Misapplication of vulnerability enhancement; argued maximum excessive | Affirmed: although one enhancement arguably misapplied, other valid factors support within‑range sentence; no abuse of discretion |
| Admissibility of prior convictions for impeachment | (State) Ruling that priors admissible should be presumed correct because record on pretrial ruling absent | (Watts) Ruling erroneous and priors were unduly prejudicial and improper propensity evidence | Affirmed (waived): appellate review precluded because transcript/order of hearing not in record; presumption of correctness applies |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
- State v. Bishop, 431 S.W.3d 22 (Tenn. 2014) (corroboration requirement for convictions relying principally on extrajudicial confessions)
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse‑of‑discretion review of within‑range sentences and presumption of reasonableness)
- State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (trial court discretion in sentencing and review principles)
- State v. Draper, 800 S.W.2d 489 (Tenn. Crim. App. 1990) (appellate waiver when record lacks transcript of contested proceeding)