State of Tennessee v. Melvin King, E2016-01043-CCA-R3-CD

On June 26, 2014, Melvin King and several codefendants entered a Knoxville home during an attempted robbery/robbery of suspected drug sellers; during the incident the homeowner, John Huddleston, was shot multiple times and died; two dogs were shot and a house occupant (Sydney Smith) was wounded.
King drove to the house, participated in the armed entry (wore a face covering), threatened residents (pointed a .40 caliber handgun at victims, demanded drugs/money), and was identified at trial by victims and codefendants; shell casings at the scene matched a .40 handgun found nearby.
Several codefendants pled guilty and some testified for the State; King made inculpatory jailhouse statements to another inmate admitting multiple gunshots were fired.
A Knox County jury convicted King of multiple counts including first-degree murder, aggravated burglary, employing a firearm during a dangerous felony, three counts of especially aggravated kidnapping, attempted especially aggravated robbery counts, reckless aggravated assault, and aggravated animal cruelty; he received an effective life sentence.
King appealed, challenging (1) sufficiency of evidence for dual kidnapping/attempted robbery convictions, (2) admission of autopsy photographs, and (3) the flight jury instruction. The Court affirmed but remanded for entry of missing judgment forms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for especially aggravated kidnapping & attempted especially aggravated robbery	State: evidence (witness IDs, guns, threats, victims confined/removed) supports convictions	King: kidnappings were incidental to robbery; no robbery of some victims; White requires greater confinement than necessary	Affirmed: victims of kidnapping were different from robbery victims; under Teats/Williams due-process concern not present; evidence supports convictions
Admission of autopsy photographs	State: photos relevant to show number/trajectory of gunshot wounds; aid jury understanding	King: cause of death not disputed; photos more prejudicial than probative	Affirmed: trial court did not abuse discretion under Tenn. R. Evid. 401/403 and Banks factors; photos informative, not unduly prejudicial
Flight jury instruction	State: evidence of leaving the scene supported instruction	King: left scene but did not hide from police or attempt to evade capture	Affirmed: flight instruction proper where defendants fled scene; return to scene irrelevant
Procedural defect: judgment forms missing	State: not disputed	King: raised on appeal	Remanded: trial court must enter separate judgment forms for listed counts

State v. White, 362 S.W.3d 559 (Tenn. 2012) (White instruction: removal/confinement must be greater than that necessary to commit accompanying felony)
State v. Teats, 468 S.W.3d 495 (Tenn. 2015) (White instruction not required when kidnapping and robbery involve different victims)
State v. Williams, 468 S.W.3d 510 (Tenn. 2015) (same principle: kidnapping of one victim cannot be incidental to offense against a different victim)
State v. Alston, 465 S.W.3d 555 (Tenn. 2015) (aggravated burglary with kidnapping, standing alone, does not always warrant White instruction)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review: any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Banks, 564 S.W.2d 947 (Tenn. 1978) (framework for admissibility of graphic photographs under Rule 403)
State v. Davidson, 509 S.W.3d 156 (Tenn. 2016) (trial court must enter separate judgment forms for each count)