State of Tennessee v. Santos Morales
W2019-02019-CCA-R3-CD
Tenn. Crim. App.Jul 9, 2021Background
- December 18–19, 2016: seven-year-old victim slept at a friend’s house where defendant Santos Morales was a visitor.
- Victim testified that an unfamiliar man entered the dark bedroom twice and touched her vaginal area under her panties; she later indicated the defendant looked like that man.
- Victim’s mother found the defendant asleep on the living-room floor the same night, then confronted him the next morning; mother and sibling corroborated that the victim identified the defendant.
- Sibling J.E. testified he saw "Santos" leaving the children’s room covering his face; he said Mr. Morales and Mr. Qualls were not in the children’s room.
- Forensic interview was conducted; a recorded jail call (played at trial) included the defendant suggesting offering money to keep the victim from appearing.
- Jury convicted Morales of aggravated sexual battery; trial court imposed 10 years at 100% and sexual-offender registration. Morales appealed asserting insufficient evidence as to identity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence (identity) | Evidence (victim ID, mother corroboration, sibling observation, forensic interview, jail call) establishes identity beyond a reasonable doubt | Identity not proven; victim uncertain and exhibits/recordings incomplete on appeal | Conviction affirmed — circumstantial and direct evidence sufficient for a rational jury to find identity beyond a reasonable doubt |
| Incomplete appellate record (missing exhibits/recordings) | Record adequate; missing exhibits should be presumed to support trial court | Missing exhibits impede meaningful appellate review | Court applied Caudle presumption that missing items would support the trial court where record is adequate and proceeded to review; affirmed judgment |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of the evidence)
- State v. Rice, 184 S.W.3d 646 (identity is an essential element)
- State v. Reid, 91 S.W.3d 247 (circumstantial evidence may establish identity)
- State v. Dorantes, 331 S.W.3d 370 (same sufficiency standard for circumstantial evidence)
- State v. Bland, 958 S.W.2d 651 (deference to jury on credibility and weight of evidence)
- State v. Caudle, 388 S.W.3d 273 (presumption that missing portions of an incomplete appellate record support the trial court when record is otherwise adequate)
