State of Tennessee v. Todd Dewayne Scruggs, M2016-00558-CCA-R3-CD

On March 18, 2015 the Seventeenth Judicial District Drug Task Force organized a controlled buy: confidential informant Kenneth Davis (cooperating for potential leniency) was given $500 in marked bills and a recording device and instructed to buy three grams of heroin.
The informant met defendant Todd Scruggs, who exited a maroon Buick, produced an off-white powdery substance, and attempted to weigh it on a digital scale; the informant later paid $500 and retained the substance and scale.
Task force agents observed, audio- and video-recorded the transaction, followed the Buick, stopped it, and found the marked $500 in Scruggs’s wallet and a digital scale on his person; testing confirmed the substance was 2.97 grams of heroin.
Scruggs was indicted, tried, and convicted by a jury of selling/delivering heroin (merged) and possessing drug paraphernalia; he was sentenced as a Range III persistent offender to an effective 26 years (heroin) concurrent with 11 months/29 days (paraphernalia).
On appeal Scruggs challenged (1) sufficiency of the evidence, arguing the confidential informant’s testimony was untrustworthy, and (2) that the 26-year within-range sentence was excessive.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Scruggs)	Held
Sufficiency of evidence to convict for sale/delivery and paraphernalia	Evidence (video/audio, marked bills, recovered heroin, witness testimony) establishes sale beyond a reasonable doubt	Informant Davis was not credible because he faced drug charges; testimony untrustworthy	Affirmed: Evidence sufficient; jury credited informant and corroboration supports convictions
Excessiveness of 26-year sentence	Sentence is within Range III; court considered presentence report, enhancements, defendant’s record and allocution	Sentence excessive given circumstances (e.g., travelled at informant’s request)	Affirmed: Within-range sentence reasonable; trial court properly applied sentencing principles and enhancements

Jackson v. Virginia, 443 U.S. 307 (established standard for reviewing sufficiency of the evidence)
Bolin v. State, 405 S.W.2d 768 (Tenn. 1966) (trial court and jury are primary factfinders; credibility determinations accorded deference)
State v. Evans, 838 S.W.2d 185 (Tenn. 1992) (appellate review of sufficiency and credibility issues)
State v. Tuggle, 639 S.W.2d 913 (Tenn. 1982) (burden on appellant to show evidence insufficient after jury verdict)
State v. Dorantes, 331 S.W.3d 370 (Tenn. 2011) (same standard for direct and circumstantial evidence)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate review of sentencing; presumption of reasonableness for within-range decisions)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (trial court may impose any sentence within the range consistent with Sentencing Act)