State of Tennessee v. Randy Joe Richards, M2017-00030-CCA-R3-CD

Defendant Randy Joe Richards was convicted by a jury of theft of property valued $10,000–$60,000 (Class C felony), vandalism (<$500), and driving on a revoked license; effective sentence 15 years as a Range III persistent offender.
Victim Robert Chumbley reported a red 2005 International tractor-trailer (value $12,500–$15,000) missing after parking it on Old Belfast Road; truck was later stopped on that road with Richards driving.
At the traffic stop officers discovered Richards’ license was revoked; Chumbley identified the truck and observed brake/tire damage consistent with misuse (costs for tires and brakes plus lost business).
Richards claimed he was performing maintenance for employer Steve Bowden; Bowden testified he was not operating a trucking business then and Richards never worked for him.
Trial court classified Richards as a Range III Persistent Offender based on multiple prior felonies and parole violations, found enhancement factors applicable, and imposed within-range sentences (15 years for theft; concurrent shorter terms for misdemeanors).
On appeal Richards challenged (1) sufficiency of the evidence for theft and (2) excessiveness of sentence; the Court affirmed both convictions and the sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for theft (Class C)	State: evidence sufficiently proved Richards knowingly exercised control over truck without owner’s effective consent and intended to deprive owner	Richards: facts only support joyriding — he took the truck toward the shop and home; no intent to permanently deprive owner	Court: Evidence sufficient; jury credited State’s witnesses and rejected Richards’ repair/joyriding theory
Sentence excessive / contrary to sentencing principles	State: trial court properly applied enhancement factors and Bise/Caudle standards; sentence within range and presumptively reasonable	Richards: 15-year effective term is greater than necessary; does not fit the crime/offender; cites jail/prison resource concerns	Court: No abuse of discretion; trial court properly considered enhancement factors, criminal history, parole status, and purposes of sentencing; within-range sentence affirmed

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
State v. Reid, 91 S.W.3d 247 (jury verdict resolves credibility; burden on appellant to show insufficiency)
State v. Goodwin, 143 S.W.3d 771 (appellate deference to prosecution’s view of evidence)
State v. Smith, 24 S.W.3d 274 (inferences and review of evidence)
State v. Wagner, 382 S.W.3d 289 (jury credibility determinations)
State v. Campbell, 245 S.W.3d 331 (credibility and conflicts entrusted to jury)
State v. Bland, 958 S.W.2d 651 (guilty verdict accredits State’s testimony)
State v. Dorantes, 331 S.W.3d 370 (sufficiency standard applies to direct and circumstantial evidence)
State v. Hanson, 279 S.W.3d 265 (same)
State v. Caudle, 388 S.W.3d 273 (presumption of reasonableness for within-range sentences)
State v. Bise, 380 S.W.3d 682 (standard for reviewing within-range sentencing decisions)
State v. Shuck, 953 S.W.2d 662 (abuse of discretion definition in sentencing)
Ballard v. Herzke, 924 S.W.2d 652 (standard for abuse of discretion review)
State v. Carter, 254 S.W.3d 335 (trial court discretion in weighing enhancement and mitigating factors)