History
  • No items yet
midpage
State of Tennessee v. Santos Morales
W2019-02019-CCA-R3-CD
Tenn. Crim. App.
Jul 9, 2021
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: State of Tennessee v. Santos Morales
Court Name: Court of Criminal Appeals of Tennessee
Date Published: Jul 9, 2021
Docket Number: W2019-02019-CCA-R3-CD
Court Abbreviation: Tenn. Crim. App.