State of Tennessee v. William Langston
W2015-02359-CCA-R3-CD
| Tenn. Crim. App. | May 12, 2017Background
- Victim Kimberly Langston was fatally shot in her home on May 24, 2013; defendant William Langston claimed the victim lunged with a knife and the gun fired accidentally after he retrieved it from a shed.
- Police found a nine-millimeter handgun wrapped in a shirt in a neighboring vacant lot; TBI ballistics expert testified the gun would fire only if the trigger was pulled and did not malfunction.
- Autopsy showed a fatal head wound with powder stippling indicating an intermediate range (6 inches–3 feet); bloodstain and trajectory evidence were contested by opposing experts.
- Langston was indicted initially for voluntary manslaughter, later superseded by a first-degree murder indictment; the trial court granted the State’s motion to nolle prosequi the manslaughter indictment, rejecting Langston’s attempt to plead guilty to it.
- A jury convicted Langston of second-degree murder; he received a mid-range 20-year sentence. On appeal he challenged (1) denial of the plea, (2) qualification of a police officer as a blood-spatter expert, (3) sequential jury instructions limiting consideration of voluntary manslaughter, (4) sufficiency of the evidence, and (5) sentence length.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Langston) | Held |
|---|---|---|---|
| Trial court refusal to accept guilty plea to original voluntary manslaughter indictment | State may dismiss pending indictment and proceed on superseding indictment; dismissal proper unless clearly contrary to manifest public interest | Langston argued he had a right to change plea to voluntary manslaughter and court should have evaluated factual basis and voluntariness before permitting dismissal | Court upheld nolle prosequi; State’s dismissal of the manslaughter indictment was not clearly contrary to manifest public interest, so plea was properly refused. |
| Qualification of Lt. Mullins as blood-spatter expert | Lt. Mullins’ training and extensive homicide experience made his testimony helpful and admissible under Tenn. R. Evid. 702 | Langston argued Mullins lacked advanced training, peer review, methodological reliability, and his opinions were speculative | Court found trial court did not abuse discretion — Mullins admissible; methodological concerns went to weight, not admissibility. |
| Sequential jury instructions (order of considering murder then manslaughter) | Instructions were consistent with Tennessee precedent and statutory elements; jurors may weigh passion/provocation when appropriate | Langston argued sequential instructions effectively prevented jurors from considering voluntary manslaughter and violated due process | Court held instructions were not prejudicially erroneous though not ideal; recommended using current pattern instructions placing the distinction in both charges. |
| Sufficiency of the evidence to support second-degree murder | State relied on testimony (gun required trigger pull, intermediate-range stippling, reentry with gun) to show a knowing killing | Langston contended provocation and knife threat reduced culpability to voluntary manslaughter or lesser offenses | Court affirmed conviction: viewed in light most favorable to State, a rational juror could find a knowing killing beyond a reasonable doubt. |
| Sentence length (20 years mid-range) | Trial court considered factors, applied one enhancement (use of firearm) and relevant mitigation, articulated reasons and gave due weight | Langston argued trial court ignored mitigating factors (provocation, assistance locating gun, remorse, low criminal history) | Court upheld sentence as within-range and not an abuse of discretion; trial court properly considered purposes and factors. |
Key Cases Cited
- State v. Harris, 33 S.W.3d 767 (Tenn. 2000) (prosecutor discretion to obtain superseding indictment and limited judicial review of dismissal)
- McDaniel v. CSX Transp., Inc., 955 S.W.2d 257 (Tenn. 1997) (factors for evaluating reliability of expert testimony)
- State v. Scott, 275 S.W.3d 395 (Tenn. 2009) (trial court gatekeeper role on expert admissibility)
- State v. Davidson, 509 S.W.3d 156 (Tenn. 2016) (standards for expert qualifications and admissibility)
- State v. Williams, 38 S.W.3d 532 (Tenn. 2001) (distinguishing second-degree murder and voluntary manslaughter)
- State v. Brown, 311 S.W.3d 422 (Tenn. 2010) (second-degree murder as result-of-conduct and knowing mental state)
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate review of sentencing and presumption of reasonableness for within-range sentences)