State of Tennessee v. Curtis Lee Majors

Summary

The Tennessee Supreme Court held that under Tenn. Code Ann. § 39-16-503(a)(1) the State need not prove the specific identity of the 'thing' a defendant altered, destroyed, or concealed, because 'thing' by definition embraces objects or entities not precisely designable. Viewing the proof most favorably to the prosecution, the court held the circumstantial evidence — Defendant's flight from announced officers, the instantaneous flush, his fully dressed state while the tank refilled, water splattered on the seat, his repeated 'I snort' responses, his admitted cocaine ownership, and expert testimony that flushed cocaine is unrecoverable — excluded every other reasonable hypothesis and sustained the tampering conviction. The court further held the indictment tracking the statutory language was not constitutionally deficient (plain error not established) and that a jury instruction using the statutory language without naming the 'thing' was not erroneous. The judgments of the trial court and the Court of Criminal Appeals were affirmed.