State of Tennessee v. Mitchell Blake Puckett, M2015-01938-CCA-R3-CD

On Dec. 17, 2013, James Jameson drove past Mitchell Puckett and another man walking in the road; after being told to move, Puckett produced a pistol, pointed it at Jameson for ~30–60 seconds, then fired two shots at Jameson’s vehicle.
One bullet struck the rear passenger door/window; shell casings and an unfired/jammed round were recovered near where Puckett stood.
Police located Puckett hiding in a residence; officers recovered a fully loaded 9mm semi-automatic (which Puckett admitted buying three days earlier) and a backpack with ammunition.
In a recorded interview, Puckett said the shooting “wasn’t planned,” that he “snapped,” described stepping back, firing, then firing again as the victim drove away, and acknowledged prior bipolar medication.
The jury convicted Puckett of attempted first-degree (premeditated) murder; he conceded attempted second-degree murder but appealed, arguing insufficient proof of premeditation.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Puckett)	Held
Whether evidence was sufficient to prove premeditation for attempted first-degree murder	Conduct (pointing gun, holding it 30–60s, firing at victim’s head while victim fled), recovered casings/unfired round, hiding and reloading show reflection and intent to kill	Shooting was impulsive: “snapped,” not planned; insufficient time for premeditation/deliberation	Affirmed: evidence sufficient to infer premeditation and support attempted first-degree murder conviction

Tuggle v. State, 639 S.W.2d 913 (Tenn. 1982) (standard for appellate review of sufficiency)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (reasonable-doubt sufficiency standard on appeal)
Williams v. State, 657 S.W.2d 405 (Tenn. 1983) (appellate view of evidence in light most favorable to State)
Pruett v. State, 788 S.W.2d 559 (Tenn. 1990) (credibility and weight of evidence for jury)
Pendergrass v. State, 13 S.W.3d 389 (Tenn. Crim. App. 1999) (direct and circumstantial evidence may sustain conviction)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same sufficiency standard for circumstantial evidence)
State v. Pike, 978 S.W.2d 904 (Tenn. 1998) (factors to infer premeditation)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (premeditation factors)
State v. Lewis, 36 S.W.3d 88 (Tenn. Crim. App. 2000) (lack of provocation/failure to render aid as factors)
State v. Davidson, 121 S.W.3d 600 (Tenn. 2003) (non-exhaustive list of premeditation evidence)
State v. Nichols, 24 S.W.3d 297 (Tenn. 2000) (distinguishing deliberation from premeditation)
State v. Dellinger, 79 S.W.3d 458 (Tenn. 2002) (noting statutory removal of deliberation element)