State of Tennessee v. Taris C. Frazier, M2016-02397-CCA-R3-CD

Defendant Taris C. Frazier was tried by a Rutherford County jury for events on Oct. 28–29, 2014 at a Murfreesboro residence; convicted of three counts each of especially aggravated kidnapping and aggravated assault, plus resisting arrest and criminal impersonation; effective 75-year sentence affirmed on appeal.
Victims Teresa Ring, Lauren Oldfield, and Amber Waight testified the Defendant confined them to a bedroom/house for hours, beat Ring and Oldfield with fists, threatened them with a knife and a beer bottle, and prevented them from leaving; one victim escaped to a McDonald’s to summon police.
Police responded to 911 calls, breached the house after failed commands and robot deployment, found victims and located the Defendant hiding under clothing; a bent paring knife was recovered behind a TV.
Victim injuries and the circumstances (forced confinement, threats with a knife, inability to leave, and victims’ fear) supported charges for especially aggravated kidnapping (substantial interference with liberty by use of a deadly weapon) and aggravated assault (placing victims in reasonable fear by use/display of a deadly weapon).
Defendant challenged convictions on appeal arguing victim credibility (drug use, prior convictions, inconsistent statements) and asserting victims were free to leave; the jury credited the State’s witnesses and convicted.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Frazier)	Held
Sufficiency of evidence for especially aggravated kidnapping	Evidence shows unlawful confinement/substantial interference by threats/use of a deadly weapon (knife/beer bottle) and victims’ fear; therefore sufficient	Victims lacked credibility (drug use, prior convictions, inconsistencies); proof did not show they were not free to leave	Affirmed: viewed in State's favor, evidence supports confinement by use/threat of deadly weapon and interference with liberty
Sufficiency of evidence for aggravated assault	Evidence shows intentional/knowing conduct using/displaying a deadly weapon causing reasonable fear of imminent bodily injury	Same credibility and freedom-to-leave arguments	Affirmed: victims reasonably feared imminent injury from knife/beer bottle; evidence sufficient
Credibility of victims	State relies on jury’s factfinding and demeanor-based credibility determinations	Challenges credibility based on intoxication, prior convictions, inconsistencies	Rejected on appeal: credibility determinations are for the jury; convictions stand
Whether errors in investigative/testimonial details undermine convictions	Prosecutor: procedural conduct and evidence collection corroborate victims’ accounts (injuries, recovered knife, police breach)	Defense points to omissions/inconsistencies in reports and witnesses’ statements	Court held record overall corroborates victims; no reversible insufficiency

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
State v. Evans, 838 S.W.2d 185 (Tenn. 1992) (appellate review of criminal convictions and sufficiency analysis)
State v. Anderson, 835 S.W.2d 600 (Tenn. Crim. App. 1992) (deference to jury credibility findings)
State v. Pappas, 754 S.W.2d 620 (Tenn. Crim. App. 1987) (weight and credibility of evidence resolved by trier of fact)
State v. Grace, 493 S.W.2d 474 (Tenn. 1973) (jury verdict accredits State witnesses and resolves conflicts in State's favor)
Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (rationale for deference to trial factfinder on witness demeanor)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on appellant to show insufficiency after conviction)