State of Tennessee v. Raynella Dossett Leath
461 S.W.3d 73
| Tenn. Crim. App. | 2013Background
- Victim killed March 13, 2003; Leath was last to see the victim alive.
- Defendant was retried after a mistrial in the first trial; initial mistrial occurred with jury hung on greater offense and lesser offenses.
- Estate planning documents and quitclaim deeds showed potential financial motive favoring Leath.
- Forensic evidence showed non-suicide homicide; drugs found in victim's blood but no drugs in Leath's home.
- Defense presented alibi/witness testimony; State argued circumstantial identity and premeditation.
- Trial court admitted estate documents, blood/urine test results challenged under Ferguson, and addressed various jury instructions and procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Double jeopardy on retrial after mistrial | Leath consented to mistrial; retrial permissible. | Mistrial violated federal/state double jeopardy protections due to improper procedures. | Retrial affirmed; consent and manifest necessity found; not barred by double jeopardy. |
| Admissibility of victim’s blood/urine test results | Ferguson analysis not triggered; destruction was policy-based and not prejudicial. | State had duty to preserve samples; destruction requires exclusion. | No Ferguson error; no duty to preserve controls; trial court proper in denial. |
| Admissibility of estate planning documents | Documents show possible financial motive and relevance to motive. | Evidence is irrelevant and highly prejudicial. | Admission not an abuse of discretion; probative value outweighed prejudice. |
| Admission of 404(b) evidence (witness fear testimony) | Evidence of fear not a prior bad act; admissible to impeach credibility if relevant. | Testimony improperly suggested prior bad acts to inflame jury. | No reversible error; court did not abuse discretion; not a 404(b) error. |
| Sufficiency of the evidence for first-degree murder | Evidentiary record supports identity, premeditation, and homicide. | Circumstantial evidence insufficient to exclude alternate explanations. | Sufficient evidence to sustain conviction under Dorantes standard; credibility for jury. |
Key Cases Cited
- State v. Mounce, 859 S.W.2d 319 (Tenn. 1993) (manifest necessity for mistrial; consent in certain circumstances)
- State v. Houston, 328 S.W.3d 867 (Tenn. Crim. App. 2010) (double jeopardy when no actual mistrial declared; consent and opportunity to object)
- State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (sufficiency standard for circumstantial evidence; Dorantes changed standard)
- Ferguson v. State, 2 S.W.3d 912 (Tenn. 1999) (preservation and balancing test for destroyed evidence; material exculpatory value)
- Christian v. State, 555 S.W.2d 863 (Tenn. 1977) (alibi jury instructions defining burden of proof)
- State v. Biggs, 218 S.W.3d 643 (Tenn. Crim. App. 2006) (thirteenth juror concept; appellate review of weight of evidence)