State of Tennessee v. William Rolandus Keel, M2016-00354-CCA-R3-CD

Defendant William Rolandus Keel, former stepfather, was tried twice for two counts of rape of a child based on two incidents in 2011–2012 where the victim (born 2000) alleged forced oral sex. First trial ended in a mistrial; second trial (Dec. 2015) proceeded with defendant representing himself with "elbow counsel."
Victim disclosed to her grandmother, triggering a DCS referral; forensic interview (May 2012) was recorded and played for the jury; medical exam days later showed no physical trauma and low likelihood of recoverable DNA.
Defense presented DCS witness notes suggesting the victim had not reported abuse in earlier DCS contacts and argued potential problems with the forensic interview; State relied on the victim’s recorded interview and testimony.
Jury convicted Keel on both counts; trial court sentenced him to 30 years for each count, served at 100%, ordered consecutively for an effective 60-year term.
On appeal Keel challenged (1) trial court’s denial of his motion to review additional DCS records (after an in camera review), (2) exclusion of his proffered expert (Dr. William Bernet) who would critique interview techniques, and (3) portions of sentencing (application/misapplication of enhancement and mitigating factors and consecutive sentencing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court’s denial of access to DCS records	State: in camera review was conducted and records contained no exculpatory or material information	Keel: additional DCS records (post-March 2012) likely contained material/exculpatory statements under Brady/Ritchie	Court affirmed: in camera review showed no Brady material; no suppression occurred
Exclusion of defense expert (Dr. Bernet)	State: expert’s methodology, relevance, and reliability were insufficient under Rules 702/703 and risked juror confusion	Keel: Bernet would show interview flaws and mechanisms producing false allegations, undermining victim’s credibility	Court affirmed exclusion: testimony irrelevant given victim’s age, risked confusion/prejudice, and lacked reliable methodology; no abuse of discretion
Sentencing — enhancement/mitigating factors	State: trial court properly applied factors and complied with sentencing principles	Keel: misapplied enhancement (gratification) and failed to apply mitigating factor (no serious bodily injury)	Court affirmed sentence: within-range, trial court considered factors, any misapplication did not show a departure from the Sentencing Act; consecutive issue waived for inadequate briefing
Consecutive sentencing challenge	State: sentencing discretion and statutory criteria satisfied	Keel: asserted incorrect application of consecutive sentencing statute	Court: claim waived for lack of developed argument; no review granted

Pennsylvania v. Ritchie, 480 U.S. 39 (principles on disclosure of confidential records and in camera review under due process)
Brady v. Maryland, 373 U.S. 83 (prosecution’s duty to disclose exculpatory evidence)
United States v. Bagley, 473 U.S. 667 (materiality standard for impeachment/exculpatory evidence)
McDaniel v. CSX Transp., Inc., 955 S.W.2d 257 (Tenn.) (standards for admissibility of expert testimony)
State v. Bise, 380 S.W.3d 682 (Tenn.) (presumption of reasonableness for within-range sentences and review of sentencing determinations)