State of Tennessee v. Matthew Thomas Dotson
E2019-01614-CCA-R3-CD
Tenn. Crim. App.Jul 27, 2021Background
- Two-year-old Clifford W. Dotson died on May 3, 2012; cause of death: malnutrition and dehydration due to prolonged starvation.
- Parents Matthew T. Dotson (defendant) and Amanda A. Dotson were indicted; Amanda pled guilty and testified for the State.
- Police interviewed Matthew at the Lerchen Road residence May 3 (unwarned) and again May 7 (Miranda waiver signed); he gave written statements.
- Trial evidence included autopsy testimony and photographs, household and DCS evidence of filthy/soiled bedding, moldy baby food, and attempts by Matthew to clean/alter the scene.
- Jury convicted Matthew of first-degree felony murder (two counts based on aggravated child abuse and aggravated child neglect), aggravated child abuse, and aggravated child neglect; sentenced to life without parole.
- Appellate court affirmed convictions but remanded to correct merger of counts and for entry of sentences on Counts 4 and 5.
Issues
| Issue | Plaintiff's Argument (State/Dotson) | Defendant's Argument (Dotson) | Held |
|---|---|---|---|
| Motion to suppress May 3 statements (Miranda/custody) | Statements admissible: Dotson was not in custody; he agreed to speak at home, moved freely, questioning not accusatory | Statements should be suppressed: custodial interrogation without Miranda; Dotson felt restricted and unable to leave | Court: Not custodial under totality (Anderson factors); statements admissible |
| Motion for mistrial / prosecutorial misconduct over testimony re: pain medication | Testimony was unsolicited by witness; State did not deliberately elicit; no manifest necessity for mistrial | Witness violated pretrial agreement; testimony about drug/pain medicine prejudiced jury and warranted mistrial | Court: No mistrial. Comments were unsolicited; defense declined curative instruction; prosecutorial-misconduct claim waived for appeal |
| Admission of victim photographs (gruesome evidence) | Highly probative to show prolonged starvation, rebut Dotson’s claimed lack of knowledge; testimony alone insufficient | Photographs cumulative and inflammatory; prejudicial effect outweighed probative value | Court: Photographs admissible; probative value outweighed prejudice; no abuse of discretion |
| Sufficiency of evidence for convictions (abuse, neglect, felony murder) | Evidence shows Dotson lived with child or saw him, knew of deterioration, failed to get care, and altered scene; medical proof of prolonged starvation | Dotson argued he did not live there during the relevant period and his testimony was more credible | Court: Evidence sufficient for aggravated child abuse, aggravated child neglect, and felony murder (jury credited State’s evidence) |
| Merger / sentencing of convictions (raised by court) | N/A — State sought convictions as charged | N/A — Dotson didn’t raise merger issue | Court: Merge duplicate felony-murder counts (Count 3 into Count 2); aggravated child abuse and neglect are not lesser-included to felony murder — remand to amend judgments and impose sentences on Counts 4 & 5 |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings requirement for custodial interrogation)
- State v. Anderson, 937 S.W.2d 851 (Tenn. 1996) (totality-of-circumstances test for custodial interrogation)
- Jackson v. Virginia, 443 U.S. 307 (standard of review for sufficiency of the evidence)
- State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (criminal responsibility and circumstantial-evidence principles)
- State v. Banks, 564 S.W.2d 947 (Tenn. 1978) (Rule 403 balancing factors for admission of gruesome photographs)
- State v. Cribbs, 967 S.W.2d 773 (Tenn. 1998) (merger rule where multiple counts charge single homicide)