State of Tennessee v. Scottie Lee Mofield, M2016-02364-CCA-R3-CD

In June 2015 Robert Vaughn was severely beaten in a convenience‑store parking lot; injuries included multiple facial fractures and permanent blindness in his right eye.
Defendant Scottie Lee Mofield, codefendant Ricky Palmer, and codefendant Maria ("Piggy") Flowers were tried jointly; Mofield and Palmer convicted of aggravated assault, Flowers convicted of reckless aggravated assault.
Vaughn identified Mofield and the others at trial; testimony described repeated kicking and punching by multiple assailants. Flowers testified she knocked a beer bottle from Vaughn and that a fight ensued; Palmer later made jail‑call statements taking responsibility.
At sentencing the trial court found no mitigators, applied enhancement factors including prior convictions, that defendant was a leader in the offense, the victim suffered particularly great injuries, and that the defendant was on probation; it imposed an eight‑year Range II sentence consecutive to an unrelated sentence.
Mofield moved for a new trial based on newly discovered evidence (Palmer’s jail call in which Palmer said he ‘‘finished’’ the victim and that Mofield and Flowers didn’t touch him); the trial court denied the motion.
On appeal the Tennessee Court of Criminal Appeals affirmed, holding the sentence and denial of a new trial were within the trial court’s discretion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Mofield)	Held
Sentencing — application of enhancement factor for leadership	Trial court properly applied statutory enhancement factors and considered record evidence	Trial court erred applying enhancement for being a leader and failed to apply two mitigators (minor role; conduct didn’t cause serious injury)	Affirmed: record supports applying enhancement (defendant admitted striking victim; victim’s testimony showed active participation); no mitigators accepted
Sentence length and consecutive service	Eight‑year within‑range sentence and consecutive term appropriate given criminal history and seriousness	Eight years and consecutive service were excessive	Affirmed: trial court considered sentencing principles and did not abuse discretion
Motion for new trial — newly discovered evidence standard	Jail‑call was not likely to change verdict; it only impeached testimony	Jail‑call was newly discovered exculpatory evidence warranting a new trial or severance	Affirmed denial: jail call impeached/co‑contradicted trial evidence but would not likely produce acquittal; defendant did not claim actual innocence pretrial
Whether impeachment evidence can mandate new trial	N/A (inherent in State’s position)	Impeaching evidence was so crucial that it probably would have produced acquittal	Denied: impeachment alone insufficient unless it would probably result in acquittal; here jury credibility findings stand

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (standard of review for within‑range sentencing and presumption of reasonableness)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (factors a trial court must consider at sentencing)
State v. Moss, 727 S.W.2d 229 (Tenn. 1986) (sentencing considerations)
State v. Taylor, 744 S.W.2d 919 (Tenn. Crim. App. 1987) (sentencing considerations)
State v. Nichols, 877 S.W.2d 722 (Tenn. 1994) (requirements for new trial based on newly discovered evidence)
State v. Goswick, 656 S.W.2d 355 (Tenn. 1983) (newly discovered evidence standard)
State v. Sheffield, 676 S.W.2d 542 (Tenn. 1984) (impeaching evidence generally insufficient for new trial)
State v. Singleton, 853 S.W.2d 490 (Tenn. 1993) (exception when impeaching evidence is likely to produce acquittal)
State v. Caldwell, 977 S.W.2d 110 (Tenn. Crim. App. 1997) (trial court discretion on new trial motions)
State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (appellate courts do not reweigh evidence; credibility for jury)
State v. Freeman, 943 S.W.2d 25 (Tenn. Crim. App. 1996) (enhancement factor for leadership does not require sole leadership)
State v. Hicks, 868 S.W.2d 729 (Tenn. Crim. App. 1993) (discussion of leadership enhancement)