State of Tennessee v. Philemon Alexander, W2015-02494-CCA-R3-CD

On Feb 17–18, 2014 a red Mustang convertible (VIN 1FAFP4441YF207067; value $6,999) was stolen from I-Finance-Auto; its GPS was disabled within an hour.
Defendant advertised the car on Craigslist, met buyers (Wilkins, his girlfriend and siblings), let them test-drive the car, and sold it for $2,500, giving a bill of sale and a false name.
Police stopped Wilkins shortly after purchase for no tag, ran the VIN, and discovered the car had been reported stolen; Wilkins and companions were arrested and produced the bill of sale.
Latent-print analysis of the bill of sale matched ten prints to the Defendant; witnesses (Wilkins, his sister, and girlfriend) later identified the Defendant in a second photo lineup, citing distinctive teardrop face tattoos.
Defendant was indicted for theft of property ($1,000–$10,000); a jury convicted and the trial court sentenced him to eight years. The Defendant appealed, arguing insufficiency of the evidence because there was no proof he drove the Mustang from the lot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to prove theft of property ($1,000–$10,000)	Evidence (VIN match, sale shortly after theft, bill of sale with Defendant’s fingerprints, eyewitness IDs) supports conviction	No proof Defendant possessed or drove the car from the dealership; insufficient to sustain theft conviction	Affirmed. Viewing evidence in the light most favorable to the State, a rational jury could find elements beyond a reasonable doubt; possession and sale shortly after theft permits inference of theft

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
State v. Sheffield, 676 S.W.2d 542 (Tenn. 1984) (deference to jury on conflicts in testimony)
State v. Cabbage, 571 S.W.2d 832 (Tenn. 1978) (appellate review standards)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (credibility and weight are jury functions)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on appellant to show insufficiency after conviction)
State v. Pendergrass, 13 S.W.3d 389 (Tenn. Crim. App. 1999) (sufficiency standard applies to direct and circumstantial evidence)
State v. March, 293 S.W.3d 576 (Tenn. Crim. App. 2008) (theft by obtaining or exercising control)
State v. James, 315 S.W.3d 440 (Tenn. 2010) (possession of recently stolen property permits inference of theft unless satisfactorily explained)