State of Tennessee v. Steven Dare Steelman, Jr.
E2017-00016-CCA-R3-CD
| Tenn. Crim. App. | Oct 30, 2017Background
- On Nov. 23, 2014, Steven D. Steelman, Jr. lost control of his vehicle; the front passenger (his son/relative) died of blunt force trauma and a rear-seat child (Nathan Lawson) suffered three spinal fractures. The crash involved impact with a telephone pole and a tree.
- Officers smelled alcohol on Steelman; he admitted drinking moonshine the prior night and using marijuana. He consented to blood draw; TBI analysis showed BAC 0.144% and presence of marijuana metabolites.
- Crash reconstruction found no mechanical failure, no evidence of swerving to avoid an oncoming car, and concluded the driver was impaired and failed to maintain control.
- A jury convicted Steelman of aggravated vehicular homicide (based on two prior DUI convictions), vehicular homicide (intoxication and reckless), vehicular assault, reckless endangerment with a deadly weapon, third-offense DUI/DUI per se, driving on revoked license, and failure to provide proof of financial responsibility.
- The trial court merged several counts at sentencing and imposed an effective 32-year sentence (20 years for aggravated vehicular homicide; 12 years for vehicular assault; other terms concurrent).
- On appeal Steelman challenged (1) sufficiency of evidence for aggravated vehicular homicide and vehicular assault, (2) double jeopardy/merger between certain convictions, and (3) sentence length.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Steelman) | Held |
|---|---|---|---|
| Sufficiency — aggravated vehicular homicide (intoxication as proximate cause) | Evidence (BAC 0.144%, officer observations, reconstructions) shows intoxication caused the crash. | Intoxication did not proximately cause the crash; he swerved to avoid an oncoming vehicle. | Conviction affirmed: evidence sufficient to prove intoxication was proximate cause. |
| Sufficiency — vehicular assault (serious bodily injury to Lawson) | Lawson was under 12 at crash and suffered three spinal fractures → meets statutory "serious bodily injury." | Injuries were not life‑threatening, unconsciousness/disfigurement absent; child-broken-bone rule inapplicable if over 12. | Conviction affirmed: Lawson was under 12 at time and injuries qualify as serious bodily injury. |
| Double jeopardy — vehicular assault v. reckless endangerment (deadly weapon) | Both offenses arise from same act but have different elements (intoxication + serious injury for vehicular assault; only recklessness and danger for reckless endangerment). | Argued they duplicate punishment and should merge under Blockburger/Watkins. | No plain error: elements differ and dual convictions allowed; merger denied. |
| Double jeopardy (plain error) — vehicular assault v. DUI/DUI per se | Vehicular assault subsumes DUI; separate punishment for DUI and vehicular assault for same act is improper. | Not raised at trial; issue raised by court sua sponte on appeal? | Court recognized plain error: DUI convictions merge into vehicular assault; remanded to enter corrected judgments. |
| Sentencing — excessive / consecutive service | State: trial court properly applied enhancement factors and discretion to impose consecutive sentences given extensive record. | Sentence (32 years) excessive; argued remorse and lack of intent to kill. | Affirmed: within statutory ranges; enhancement factors and consecutive service supported by record; no abuse of discretion. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
- Blockburger v. United States, 284 U.S. 299 (same‑elements test for double jeopardy)
- State v. Watkins, 362 S.W.3d 530 (Tenn. adoption of Blockburger analysis)
- State v. Rhodes, 917 S.W.2d 708 (DUI is lesser‑included offense of vehicular assault)
- State v. Bise, 380 S.W.3d 682 (standard of review and presumption of reasonableness for within‑range sentencing)