State of Tennessee v. Michael Lynch, E2020-00930-CCA-R3-CD

Defendant Michael Lynch was indicted on six counts for thefts of multiple HVAC units taken from three separate business properties in Knoxville; charges camedown to two counts related to Paul’s Oasis, two to Weisbrook Drive, and two to Penn Station.
Police conducted surveillance after an anonymous tip; officers observed HVAC parts at Lynch’s residence and stopped a truck with Lynch and co-defendant Steven Phillips (Phillips had an outstanding warrant).
Officers found air-conditioning components in the truck bed and at Lynch’s property; Lynch was transported to the station, given Miranda warnings, signed a waiver, and made inculpatory statements; Phillips later implicated Lynch and testified for the State.
Surveillance video and eyewitness testimony linked the truck to the thefts; Phillips pled guilty and was an accomplice witness at trial; the jury convicted Lynch on all counts and the court merged counts into three convictions (theft > $10,000; theft > $2,500; attempted theft > $2,500).
Lynch was sentenced to an effective term of 15 years and appealed, arguing (1) the denial of a suppression motion, (2) denial of severance, and (3) admissibility of prior convictions (the last was abandoned on appeal); he also challenged the sufficiency of the evidence.

Issue	State's Argument	Lynch's Argument	Held
Denial of severance (joinder of offenses)	Offenses were part of a common scheme/plan (similar method, close in time); evidence of each would be admissible in others	Offenses were separate opportunistic crimes and should be tried separately	Trial court did not abuse discretion; joinder proper because offenses were similar, temporally related, and identity was at issue
Motion to suppress — seizure/probable cause	Officers had probable cause based on tip corroborated by surveillance and observed HVAC parts	Stop/arrest and transport to station was an unreasonable seizure	Court found probable cause for arrest; suppression properly denied
Motion to suppress — post-arrest statements/Miranda waiver	Lynch waived Miranda in writing and spoke voluntarily; he did not unequivocally invoke right to silence or counsel	Lynch contended he invoked his right to remain silent and statements were product of custodial interrogation after invocation	Court held Lynch did not unequivocally invoke rights; waiver was voluntary and statements admissible
Sufficiency of evidence (including accomplice corroboration)	Phillips’ testimony, surveillance video, officer observations and victim testimony corroborated crimes and identity	Lynch denied intentional theft or claimed belief he had permission at some sites	Evidence—direct and circumstantial—was sufficient; jury rejection of Lynch’s account upheld

State v. Shirley, 6 S.W.3d 243 (Tenn. 1999) (standard of review and abuse of discretion for joinder/severance)
Spicer v. State, 12 S.W.3d 438 (Tenn. 2000) (severance inquiry focuses on evidentiary relevance and common scheme analysis)
State v. Moore, 6 S.W.3d 235 (Tenn. 1999) (common scheme/severance principles)
State v. Hoyt, 928 S.W.2d 935 (Tenn. Crim. App. 1995) (common scheme for severance same as evidentiary common scheme)
State v. Denton, 149 S.W.3d 1 (Tenn. 2004) (larger plan/conspiracy requires a distinguishable goal beyond a string of similar offenses)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda requirements for custodial interrogation)
Edwards v. Arizona, 451 U.S. 477 (1981) (requirement that questioning cease after an unambiguous request for counsel)
Davis v. United States, 512 U.S. 452 (1994) (invocation of right to counsel must be clear and unequivocal)
State v. Shaw, 37 S.W.3d 900 (Tenn. 2001) (accomplice testimony requires some independent corroboration linking defendant to the crime)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of the evidence standard)