State of Tennessee v. Sean Farris
W2016-01778-CCA-R3-CD
Tenn. Crim. App.Jul 12, 2017Background
- Victim was held at gunpoint on August 30, 2014, at Grahamwood Apartments in Memphis; laptop, wallet (containing U.S. and Mexican currency), and keys were taken. Victim later identified Sean Farris in a photographic lineup and at trial.
- Police located a Chevy Avalanche matching the victim’s description on September 2, 2014; three occupants were arrested, two handguns were recovered from the vehicle, and the victim’s key chain (silver hat and red tag) was found in a backyard near the co-defendant’s sister’s home.
- Officers found Mexican currency on Farris when he was detained later; Farris admitted being a back-seat passenger in the Avalanche but testified he did not see or participate in the robbery.
- Farris was convicted by a jury of aggravated robbery (deadly-weapon display) and sentenced as a Range I, standard offender to 10 years, 6 months (range 8–12 years).
- On appeal Farris challenged: (1) admission of prior convictions for impeachment, (2) limits on cross-examination of the victim, (3) sufficiency of the evidence, and (4) excessiveness/misapplication of sentencing enhancement factors.
Issues
| Issue | State's Argument | Farris's Argument | Held |
|---|---|---|---|
| Admissibility of prior convictions for impeachment | Proper: prior convictions for theft/auto burglary and criminal impersonation are crimes of dishonesty and probative of credibility; notice given | Trial court erred in admitting convictions (attempt to alter tag; theft <$500) | Admission proper; convictions relevant to credibility and probative value not outweighed by prejudice; no abuse of discretion |
| Limitation on cross-examining victim about description | Limitation was within trial court discretion; victim already testified to descriptive variations | Court unreasonably limited cross-examination that could show inconsistencies in victim’s descriptions | No abuse of discretion; record lacks offer of proof or specific inconsistencies; jury heard relevant descriptive statements |
| Sufficiency of evidence for aggravated robbery | Victim ID, recovery of keys, Mexican currency on Farris, recovered gun in vehicle, Farris’s presence in vehicle support conviction | Verdict against weight of evidence; sole eyewitness identification contradicted by Farris’s alibi/innocent presence testimony | Evidence sufficient when viewed in light most favorable to State; jury credited victim’s testimony |
| Sentence / misapplication of enhancement (hate-motivated selection) | Even if enhancement (17) misapplied, trial court legitimately relied on criminal history (enhancement 1) and sentenced within statutory range | Trial court erred by giving weight to a hate-selection factor and thus exceeding minimum | No abuse of discretion; sentence within range, trial court considered purposes/principles of Sentencing Act; misapplication of a factor alone not reversible |
Key Cases Cited
- State v. Waller, 118 S.W.3d 368 (Tenn. 2003) (factors for balancing admissibility of prior convictions for impeachment)
- State v. Roberts, 943 S.W.2d 403 (Tenn. Crim. App. 1996) (probative value vs prejudice standard for impeachment convictions)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for sufficiency of the evidence review)
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate review of within-range sentencing and presumption of reasonableness)
- Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (role of trial judge and jury in assessing witness credibility)