State of Tennessee v. Carl J. Wagner

Summary

The Tennessee Supreme Court granted the State's permission appeal to decide whether the Court of Criminal Appeals erred in declaring the evidence insufficient for the defendant's convictions of especially aggravated robbery and felony murder on the ground that his confession alone evidenced the victim's backpack and its taking. Applying the sufficiency benchmark that any rational trier of fact, viewing the evidence most favorably to the prosecution, could find the essential elements beyond a reasonable doubt, the Court found independent circumstantial proof — victim blood transferred from fabric to the courtyard railing along the defendant's flight path, photographs of the body and torn shirt, the locked laundry room door, the absence of drugs at the scene, and the defendant's own statements — sufficient for especially aggravated robbery, and found the jury's rejection of the defendant's self-defense claim sufficient for felony murder. The Court reversed the Court of Criminal Appeals' judgment and reinstated the trial court's judgment, taxing appeal costs to the State because the defendant is indigent.