State of Tennessee v. Stanley Jefferson
W2020-00578-CCA-R3-CD
| Tenn. Crim. App. | Jun 22, 2021Background
- Victim (mid-70s) was assaulted in her home on Labor Day (Sept. 7, 2015): assailant impersonated a sheriff’s deputy, forced entry, beat her unconscious, digitally penetrated her, and stole her vehicle. Victim suffered facial trauma and a small cerebellar hemorrhage.
- Forensic and physical evidence: vaginal/vulvar lacerations with active bleeding; sperm on vulvar and leg swabs; sperm/DNA from the Defendant on the car gear shift; vital-records form with Defendant’s personal data recovered from the stolen car.
- GPS ankle-monitor data placed the Defendant within ~50 meters of the victim’s address during the evening of Sept. 7; the Defendant’s STOP monitoring record produced alerts for curfew violation and presence in the area.
- The Defendant admitted to impersonating a deputy, striking the victim, stealing the car, and digitally penetrating the victim during a police interview.
- Jury convicted the Defendant of aggravated rape (by bodily injury), two counts of especially aggravated burglary, aggravated assault (lesser included), and theft; effective sentence 58 years. On appeal the Defendant challenged only sufficiency of evidence for aggravated rape; the court also identified a sentencing/clerical issue on the theft count and remanded for correction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aggravated rape (penetration and identity) | DNA (sperm on vulva/leg), vaginal lacerations, victim’s injuries, GPS presence, confession, and DNA in vehicle establish penetration and identity | No proof of penetration; victim could not identify attacker; claimant of low IQ diminishes confession reliability | Affirmed. Evidence (injuries, forensic DNA, GPS, confession, vehicle evidence) supports penetration and identity beyond a reasonable doubt |
| Sentencing classification for theft count | (State) unclear record whether savings statute applied; conviction form lists Class D | Defendant argues sentencing/grading error given statutory reclassification to Class E and savings statute | Remanded to correct/clarify the theft sentence (clerical or substantive application of savings statute) |
Key Cases Cited
- State v. Pope, 427 S.W.3d 363 (Tenn. 2013) (standard for sufficiency review)
- State v. Smith, 436 S.W.3d 751 (Tenn. 2014) (deference to jury credibility findings)
- State v. Reid, 91 S.W.3d 247 (Tenn. 2002) (verdict accredits State’s witnesses)
- State v. Hawkins, 406 S.W.3d 121 (Tenn. 2013) (view evidence in light most favorable to State)
- State v. Wagner, 382 S.W.3d 289 (Tenn. 2012) (circumstantial evidence can support conviction)
- State v. Bowles, 52 S.W.3d 69 (Tenn. 2001) (definition of penetration; entry of vulva/labia sufficient)
- Hart v. State, 21 S.W.3d 901 (Tenn. 2000) (penetration need not rupture hymen; slight intrusion suffices)
- State v. Bell, 512 S.W.3d 167 (Tenn. 2015) (identity is essential element; fact for jury)
- State v. Thomas, 158 S.W.3d 361 (Tenn. 2005) (jury resolves identity/conflicting evidence)
- State v. Hornsby, 858 S.W.2d 892 (Tenn. 1993) (jury’s role in accrediting testimony)
- State v. Menke, 590 S.W.3d 455 (Tenn. 2019) (application of savings statute to reduced theft grading)
