State of Tennessee v. Robert Brooks, W2020-01026-CCA-R3-CD

Transaction on Craigslist: Brooks responded to Crotwell’s ad for a 1992 Chevrolet Cavalier; after paying cash and receiving a signed title, the Cavalier would not restart at a Kroger gas station.
After ~30–40 minutes of failed attempts, Crotwell called friends (Jasmine Stewart and Xiomara Carmona) to pick him up in Carmona’s Toyota Solara. Brooks demanded a refund; Crotwell refused.
Brooks produced a pistol, ordered Carmona and Stewart out of the Solara (telling them to leave the keys), fired at Crotwell (one round struck his shoulder), then took Carmona’s Solara and drove away; the Solara was later recovered abandoned.
Witnesses (Crotwell, Stewart, Carmona) identified Brooks from a photographic lineup; surveillance video and physical evidence (spent casings, bullets, shell casings, the Cavalier/title found at Brooks’s uncle’s) corroborated the sequence.
Indictment included attempted second-degree murder, aggravated robbery, three aggravated assaults, and firearm enhancement; jury convicted Brooks of aggravated robbery, aggravated assaults, assault, and reckless endangerment, acquitted on the firearm enhancement; aggregate sentencing followed.
On appeal Brooks raised (1) sufficiency of the evidence for aggravated robbery (challenge to proof he knowingly stole the Solara) and (2) error in the Batson ruling when the trial court denied his peremptory strike of Juror 7 (State’s reverse Batson challenge).

Issue	State's Argument	Brooks' Argument	Held
Sufficiency of the evidence for aggravated robbery (taking Carmona’s car at gunpoint)	Evidence supported a reasonable inference Brooks intentionally/knowingly took the Solara: victims’ IDs, bystander account of a car leaving, Solara later recovered abandoned.	No direct evidence Brooks took the car; no proof of the requisite intent to steal; circumstantial evidence insufficient.	Affirmed — viewing evidence in the light most favorable to the State, a rational juror could infer Brooks knowingly/ intentionally took the Solara at gunpoint.
Batson challenge to denial of Brooks’s peremptory strike of Juror 7 (reverse Batson)	Pattern of strikes against white jurors created a prima facie case; defense’s stated reason for striking Juror 7 was pretextual given juror demeanor and similar unchallenged jurors.	Offered race-neutral reasons: Juror 7 was a farm-equipment mechanic, wife worked in warranty business, and he appeared inattentive/unresponsive.	Affirmed — trial court found a prima facie inference of discrimination, rejected the proffered race-neutral reason as pretext, and properly denied the peremptory strike.

Jackson v. Virginia, 443 U.S. 307 (1979) (standard of review for sufficiency of the evidence)
Batson v. Kentucky, 476 U.S. 79 (1986) (peremptory strikes may not be exercised on the basis of race)
Miller-El v. Dretke, 545 U.S. 231 (2005) (trial court must assess plausibility of race-neutral explanations in Batson inquiry)
Purkett v. Elem, 514 U.S. 765 (1995) (proffered race-neutral reason need not be persuasive or plausible to satisfy step two)
State v. Rice, 184 S.W.3d 646 (Tenn. 2006) (identity is an essential element; circumstantial evidence may suffice)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same standard of review for convictions based on circumstantial or direct evidence)
State v. Evans, 838 S.W.2d 185 (Tenn. 1992) (effect of guilty verdict on presumption of innocence)
State v. Hugueley, 185 S.W.3d 356 (Tenn. 2006) (Batson burden and pretext analysis)