State of Tennessee v. Terry Johnson, 366 S.W.3d 150

Tennessee Court of Criminal Appeals affirms Johnson’s conviction for aggravated robbery of a Family Dollar store in Memphis after a jury trial.
Evidence showed Johnson brandished a knife and departed with merchandise after bypassing the register.
Witnesses described Johnson’s actions inside the store at closing on October 12, 2007.
Prior September 2007 shoplifting incident involved Johnson throwing concrete at the store manager and damaging the door.
The State relied on Owens and Swift to argue about the temporal relationship between taking and violence; the defense argued the violence postdated the taking.
The trial court admitted evidence of a prior September act under Rule 404(b) for purposes including identity, intent, and context, which the court ultimately deemed harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for aggravated robbery	Johnson argues taking was completed before any violence.	Owens/Swift require contemporaneous taking and violence for robbery.	Evidence sufficient; violence contemporaneous with taking under Swift/Owens framework; affirm.
Evidentiary admissibility of the September 2007 act under Rule 404(b)	Prior act admissible to prove identity and context; not propensity.	Prejudicial; unfairly prejudicial propensity evidence.	Admission was proper for identity/intent/context; any error harmless; affirmation of conviction.

Owens v. State, 20 S.W.3d 634 (Tenn. 2000) (violent taking must precede or be contemporaneous with the taking to constitute robbery)
Swift v. State, 308 S.W.3d 827 (Tenn. 2010) (temporal proximity between taking and violence is the sole relevant factor)
State v. West, 844 S.W.2d 144 (Tenn. 1992) (Rule 404(b) exceptions for motive, identity, intent, etc.)
State v. Jones, 15 S.W.3d 880 (Tenn. Crim. App. 1999) (Rule 404(b) admissibility framework)
State v. Dubose, 953 S.W.2d 649 (Tenn. 1997) (abuse of discretion standard for 404(b) rulings)