State of Tennessee v. Royce Scott Earley, 719 S.W.3d 228

Royce Scott Earley was convicted by a jury of multiple sexual offenses, including two counts of rape of a child, two counts of incest, and one count of aggravated sexual battery, based on acts against his eight-year-old daughter and his own confession.
His confession was made after he was given and understood a Miranda warning, and he admitted to three separate incidents of abuse over the course of a month.
At trial, the prosecution presented Eyewitness testimony (from the victim's mother) and corroborating evidence, but the victim did not testify.
The trial court sentenced Earley to an effective 104-year term of imprisonment, applying statutory enhancement factors and denying all mitigation arguments.
On appeal, Earley challenged the voluntariness of his confession, the sufficiency of corroborating evidence for certain counts, and the excessiveness of his sentence.

Issue	Earley's Argument	State's Argument	Held
Voluntariness of Confession	Confession involuntary (alleged coercion, promises, and presence of armed officer)	Confession voluntary; Miranda rights given and understood	Issue waived due to lack of developed argument; affirm trial court
Sufficiency of Corroboration for Confession Counts	Counts 3-5 not corroborated per State v. Bishop standard	Mother’s eyewitness testimony and context provided sufficient corroboration	Sufficient corroboration; verdict affirmed
Excessive Sentence	Sentence excessive; mitigating factor (no serious bodily injury) should apply, and court did not follow sentencing averages	Enhanced sentence justified due to egregious conduct, position of trust, and continued denial	Sentence within discretion and law; affirmed
Admission/Sufficiency of Evidence	Entire confession improperly admitted and counts should have been acquitted	Confession and corroborating testimony sufficient for jury consideration	Confession properly admitted and jury’s verdict reasonable

State v. Bishop, 431 S.W.3d 22 (Tenn. 2014) (adopts modified trustworthiness standard for corroboration of confessions)
State v. Clark, 452 S.W.3d 268 (Tenn. 2014) (low threshold for corroboration of a confession; one corroborated key fact can suffice)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse of discretion standard applies to sentencing decisions)
State v. Pollard, 432 S.W.3d 851 (Tenn. 2013) (abuse of discretion standard also applies to consecutive sentencing)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (improper application of enhancement/mitigating factors not grounds for reversal absent departure from sentencing act)
State v. Hanson, 279 S.W.3d 265 (Tenn. 2009) (defendant bears burden of showing insufficiency of evidence on appeal)
State v. Kissinger, 922 S.W.2d 482 (Tenn. 1996) (serious bodily injury includes mental anguish in child rape cases)