State of Tennessee v. Terry Trammell
E2016-01725-CCA-R3-CD
| Tenn. Crim. App. | Jun 5, 2017Background
- Defendant Terry Trammell was tried by jury in Knox County for two counts of burglary (Class D) and two counts of theft (Class E) arising from a July 2015 break‑in at Rodem Process Equipment in which a conference‑room 40" Samsung TV was stolen.
- Employees discovered a broken rear window and the missing TV the morning after the business had closed overnight. The TV’s serial number was later matched to the victim’s records (after an initial data‑entry error).
- A fingerprint was lifted from an exterior glass shard at the broken window (the apparent point of entry) and expert examiners matched it to Trammell.
- The TV was recovered at a pawn shop; the pawn ticket bore Trammell’s name and thumbprint and showed he pawned the TV the morning the burglary was reported. He received $150.
- Trammell was convicted of both burglaries and thefts; the trial court merged related convictions and imposed concurrent sentences, ordered consecutive to a prior sentence. Trammell appealed, arguing insufficient evidence of identity and insufficient proof of value for felony classification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove identity | State: fingerprint at point of entry + pawn ticket linking defendant to TV support conviction | Trammell: only one fingerprint on exterior glass, no direct evidence he entered or took the TV | Court: Circumstantial evidence (fingerprint at entry + pawning TV within hours + matching serial number) sufficient for jury to infer identity |
| Sufficiency of evidence to prove value > $500 (felony theft) | State: owner’s lay testimony that TV (40", ~1 year old) was worth > $500; jury may use common sense to assess value | Trammell: owner not shown to be qualified to testify to value; pawn amount only $150 | Court: Defendant waived objection by not contesting admissibility at trial; lay testimony and jury common‑sense suffice to find fair market value > $500 and < $1,000 |
| Use of circumstantial evidence generally | State: circumstantial evidence can establish elements, including identity | Trammell: challenges reliance on circumstantial proof here | Court: Reiterates standard that circumstantial evidence may alone support conviction and jury weighs inferences |
| Standard of review on appeal | State: affirm convictions under Jackson v. Virginia standard | Trammell: asks for reversal on insufficiency grounds | Court: Applies Jackson standard; views evidence in light most favorable to prosecution and affirms |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency review)
- Vasques v. State, 221 S.W.3d 514 (Tenn. 2007) (appellate sufficiency review principles)
- Bland v. State, 958 S.W.2d 651 (Tenn. 1997) (credibility and weight of evidence for jury)
- Sheffield v. State, 676 S.W.2d 542 (Tenn. 1984) (appellate review limits)
- Hall v. State, 976 S.W.2d 121 (Tenn. 1998) (circumstantial vs. direct evidence)
- Dorantes v. State, 331 S.W.3d 370 (Tenn. 2011) (circumstantial‑evidence sufficiency same as direct)
- Rice v. State, 184 S.W.3d 646 (Tenn. 2006) (identity an essential element; jury decides weight)
- Reid v. State, 91 S.W.3d 247 (Tenn. 2002) (circumstantial evidence can establish identity)
- Thomas v. State, 158 S.W.3d 361 (Tenn. 2005) (identity is jury question)
- Marable v. State, 313 S.W.2d 451 (Tenn. 1958) (inferences from circumstantial evidence)
- Hamm v. State, 611 S.W.2d 826 (Tenn. 1980) (value for theft is question of fact)
- Smith v. State, 24 S.W.3d 274 (Tenn. 2000) (failure to object renders evidence admissible for jury consideration)
- Harrington v. State, 627 S.W.2d 345 (Tenn. 1981) (same principle regarding waiver and jury consideration)