State of Tennessee v. Genaro Dorantes

Summary

The Tennessee Supreme Court held that circumstantial evidence must be weighed the same as direct evidence and expressly adopted the federal standard under which the State need not exclude every other reasonable hypothesis of innocence, displacing the old Crawford 'web of guilt' formulation for appellate review. Applying that standard, the Court reinstated the defendant's aggravated child abuse conviction and affirmed his felony murder conviction, concluding the proof permitted a rational jury to find he either inflicted the abuse or was criminally responsible for Patlan's conduct. The Court also held that after the 1998 amendment, aggravated child abuse and aggravated child neglect are separate felony-murder predicates, so a murder conviction premised on aggravated child abuse cannot rest on a neglect theory. It further upheld the refusal of the defendant's special jury instruction and affirmed the enhanced twenty-two-year sentence and its consecutive service to the mandatory life term.