State of Tennessee v. Sandra Darlene Wood, M2016-01225-CCA-R3-CD

Background

Defendant Sandra Darlene Wood was convicted by a Marshall County jury of one count of cruelty to animals for failing to provide necessary food/care to horses on her farm; sentence: 11 months, 29 days, with 45 days incarceration and the remainder suspended on probation; restitution of $4,134 to Volunteer Equine Advocates (VEA).
Law enforcement and an extension agent inspected the farm after two complaints (June 2014 and April 2015); officers and an extension agent observed multiple underweight horses and little-to-no hay or feed.
Veterinarian and extension agent used the Henneke body condition score (BCS); most horses scored between 1 and 3; the mare “Mary” (State’s elected specimen) scored a 1 and later delivered an undersized foal attributed to mare malnutrition.
Expert testimony established the malnutrition developed over months (not sudden), and that removal and rehabilitation by VEA restored horses to healthy BCS levels; VEA incurred $4,134 in costs.
Defendant presented witnesses (neighbor hay seller, husband) who testified some hay purchases occurred and disputed causation; defendant testified to caretaking responsibilities and financial hardship.
Trial court admitted testimony about a prior June 2014 visit by Detective Binkley under Tenn. R. Evid. 404(b) to show knowledge and to complete the narrative; court gave a limiting instruction to the jury.

Issues

Issue	State's Argument	Wood's Argument	Held
Sufficiency of evidence to convict of cruelty to animals (Tenn. Code Ann. § 39-14-202(a)(2))	Evidence (multiple expert/official observations, BCS scores, prior warning) shows Wood knowingly failed to provide necessary food; any rational juror could convict	Evidence insufficient to prove she knowingly or intentionally failed to provide food; alternative explanations (hay purchased, winter) rebut guilt	Affirmed — evidence sufficient when viewed in State's favor; jury could find knowledge and unreasonable failure to provide food
Sentence length, confinement, denial of full probation	Sentence within misdemeanor range; enhancement factors (prior criminal history, failure to comply with alternatives) supported confinement; court properly weighed factors	Sentence excessive; court misweighed enhancements/mitigation and abused discretion in denying full probation	Affirmed — trial court acted within discretion; mitigation weighed appropriately and confinement justified
Restitution order ($4,134 to VEA)	VEA testimony supported amount; court considered defendant’s financial testimony and offered flexibility	Court failed to properly find ability to pay before ordering restitution	Affirmed — restitution amount supported by testimony and court considered defendant’s ability to pay; no abuse of discretion
Admission of Detective Binkley’s June 2014 testimony (Rule 404(b) / Rule 403)	Testimony not character evidence; admissible to show knowledge/notice and to complete the narrative; probative value outweighed prejudice; limiting instruction given	Prior-acts testimony was unfairly prejudicial, remote, and impermissible character evidence	Affirmed — trial court substantially complied with 404(b) procedures; evidence admissible to show notice/knowledge and not unduly prejudicial

Key Cases Cited

Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
Harvell v. State, 415 S.W.3d 853 (Tenn. 2013) (deference to jury credibility findings)
Bland v. State, 958 S.W.2d 651 (weighing evidence and sentencing principles)
Harris v. State, 839 S.W.2d 54 (State entitled to strongest legitimate view of evidence)
Bise v. State, 380 S.W.3d 682 (standard of review for sentencing and trial court discretion)
Caudle v. State, 388 S.W.3d 273 (review of probation denial)
Thacker v. State, 164 S.W.3d 208 (deference to trial court on 404(b) procedural compliance)
Dorantes v. State, 331 S.W.3d 370 (sufficiency review for circumstantial/direct evidence)