State of Tennessee v. Rodney Earl Jones, M2015-01373-CCA-R3-CD

Background

Victim Victor Parham was found dead at his Allen Road residence on March 15, 2012; autopsy showed multiple .380 gunshot wounds causing death.
Rodney Earl Jones (Defendant) was tried jointly with co-defendants Alberto Conde-Valentino and Xavier Tull-Morales for first-degree felony murder (felony murder during robbery) and especially aggravated robbery; jury convicted Jones of both counts; trial court imposed consecutive sentences (life + 20 years).
Key eyewitness/corroborating testimony: Ms. Pinson (neighborhood acquaintance) reported the three men planned a robbery at her apartment, returned with blood and divided proceeds; co-defendant Tull-Morales made inculpatory statements to her; Mr. Jobe testified Jones admitted planning the robbery, later disposed of a gun, sought an alibi, and helped send Tull-Morales out of town.
Investigative evidence: cell‑tower pings placed Jones’s phone near the crime scene around the murder; surveillance showed a black SUV like Jones’s nearby; DNA from a hallway door matched Conde-Valentino; five .380 casings from scene all fired from same weapon; no direct DNA/blood linking Jones to the murder weapon.
Procedural history: pretrial motions to sever were denied; Jones appealed asserting (1) erroneous denial of severance (Bruton issues), (2) trial court should have instructed jury regarding co-defendant out‑of‑court statements, and (3) insufficient evidence to support convictions.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jones)	Held
1) Denial of severance / admission of co-defendant statements (Bruton)	State: statements were either redacted, admissible as co-conspirator statements, or not elicited by prosecution; any deviation was harmless.	Jones: Ms. Pinson related co-defendant admissions that implicated Jones, violating Bruton; severance required.	Court affirmed denial: one stray statement potentially implicated Jones but was harmless in light of overwhelming independent evidence; other statements were admissible (co-conspirator or non-incriminating).
2) Failure to give jury instruction about co-defendant out-of-court statements	State: no contemporaneous request/objection; instruction not required; issue waived.	Jones: trial court should have instructed jury on limited use of co-defendant statements.	Court: issue waived for failure to request in writing; plain‑error review not warranted; no relief.
3) Sufficiency of the evidence for felony murder and especially aggravated robbery	State: circumstantial and direct evidence (planning, phone/location data, eyewitnesses, Jobe’s testimony, conduct after the crime) establishes guilt beyond a reasonable doubt.	Jones: insufficient proof he knowingly obtained/exercised control over victim’s property or was criminally responsible.	Court: evidence—planning, presence at scene, phone data, flight/disposal of gun, statements to Jobe, and conduct after—sufficient to uphold convictions under criminal responsibility theory.
4) Preservation / Waiver of objections to testimony and instructions	State: objections not made at trial; issues waived.	Jones: prior pretrial motions and trial record put the court on notice; error preserved or at least not harmless.	Court: declined to treat issues as waived in part (Bruton objection preserved), but ultimately found any Bruton error harmless; jury‑instruction omission waived and not plain error.

Key Cases Cited

Bruton v. United States, 391 U.S. 123 (1968) (non‑testifying co‑defendant confessions that implicate another defendant can violate Confrontation Clause)
Chapman v. California, 386 U.S. 18 (1967) (harmless‑error standard: reversal required unless error contributed to verdict)
Schneble v. Florida, 405 U.S. 427 (1972) (harmless‑error analysis when inadmissible confession admitted at trial)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence — whether any rational trier of fact could find guilt beyond a reasonable doubt)
Dotson v. State, 254 S.W.3d 378 (Tenn. 2008) (trial court’s denial of severance reviewed for abuse of discretion; prejudice required for reversal)