State of Tennessee v. Tylar Scott Johnson
E2024-00743-CCA-R3-CD
| Tenn. Crim. App. | Jun 5, 2025Background
- Tylar Scott Johnson was convicted by a Knox County jury of four counts of rape and one count of aggravated kidnapping after an incident involving a highly intoxicated 19-year-old University of Tennessee student.
- The defendant picked up the victim while she was intoxicated and alone, drove her for nearly two hours (including out of county), and refused to let her out when she tried to exit the vehicle.
- DNA evidence and the defendant’s admissions confirmed sexual intercourse and fellatio occurred; substantial expert testimony established the victim was too intoxicated to consent.
- The trial court imposed consecutive sentences for an effective 36-year prison term at 100% service, finding Johnson to be a "dangerous offender" with a pattern of similar behavior toward women.
- On appeal, Johnson challenged the sufficiency of the evidence, the State’s closing argument, and the imposition of consecutive sentences.
- The appellate court affirmed the convictions and sentencing, finding the trial court's decisions reasonable and supported by the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence (rape & kidnapping) | Evidence supported all elements, including non-consent and physical helplessness | Victim consented, was not physically helpless; any confinement incidental to rape | Evidence sufficient; convictions affirmed |
| State's closing argument (phone search) | Argument about defendant's refusal to consent to phone search was proper rebuttal | Improper comment on right to refuse search; plain error | No plain error; argument fair response |
| Consecutive sentencing as dangerous offender | Consecutive sentences justified by dangerous behavior and risk | No proof of no regard for life; risk not high; sentences excessive | Sentences affirmed; decision was reasoned & discretionary |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (sets standard for sufficiency of evidence review in criminal cases)
- In re Winship, 397 U.S. 358 (1970) (states must prove every element of a crime beyond a reasonable doubt)
- State v. Grace, 493 S.W.2d 474 (Tenn. 1973) (verdict accredits state’s witnesses and resolves conflicts for the State)
- State v. Bland, 958 S.W.2d 651 (Tenn. 1997) (jury's credibility determinations are given deference on appeal)
- State v. Wilkerson, 905 S.W.2d 933 (Tenn. 1995) (additional findings required for consecutive sentencing of dangerous offenders)
- State v. Pollard, 432 S.W.3d 851 (Tenn. 2013) (sets abuse of discretion review standard for consecutive sentencing)
