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State of Tennessee v. Reginald Cortez Richardson
Citation: Not availableDocket: W2006-02372-CCA-R3-CD
Court: Court of Criminal Appeals of Tennessee; October 18, 2007; Tennessee; State Appellate Court
Original Court Document: View Document
Reginald Cortez Richardson was convicted by a McNairy County jury on two counts of Class B delivery of cocaine, receiving concurrent twelve-year sentences as a Range II offender. The appeal centers on the sufficiency of the evidence supporting his convictions. The trial evidence revealed that Jason King, a confidential informant for the West Tennessee Drug Task Force, purchased cocaine from Richardson on two occasions for $100 each. During the first transaction on August 17, 2005, King initially believed he was dealing with someone else but later identified Richardson. Task force agents, having equipped King with money and a listening device, monitored the transaction. After King met Richardson, they exchanged the cocaine for cash, and King returned the drugs to the agents. The second purchase occurred on September 16, 2005, again facilitated by agents who provided King with a listening device. Richardson approached King’s vehicle and delivered cocaine in exchange for $100. Both substances, weighing .6 grams and .5 grams, were confirmed as crack cocaine by the TBI crime laboratory. Following his indictment by a grand jury for two counts of delivery of cocaine, Richardson was found guilty after a jury trial. The trial court's sentencing was affirmed upon appeal, with the court concluding that the evidence was sufficient to support the convictions. The Appellant contends that the trial evidence was insufficient to support his convictions, arguing that it relied solely on the testimony of an unreliable undercover informant, Jason King, and that the audio recordings of their interactions lacked evidentiary value due to poor quality. He questions King’s credibility, citing King’s prior theft convictions and his agreements with the State as a confidential informant, claiming this undermines the reliability of his testimony. The Appellant's appeal challenges the trial court's denial of his motion for judgment of acquittal or new trial based on insufficient evidence, though it primarily focuses on the credibility of King’s testimony. The appellate standard requires viewing evidence in the light most favorable to the prosecution, determining whether any rational trier of fact could find the essential elements of the crime beyond a reasonable doubt. The review does not involve reassessing the jury's evaluation of evidence credibility or weight, as these are exclusively jury functions. For the delivery of .5 grams or more of a Schedule II controlled substance, the prosecution must prove that the Appellant knowingly delivered the substance. It is uncontested that the substances were crack cocaine exceeding half a gram and that King identified the Appellant as the deliverer during monitored transactions. Given the evidence presented, a jury could reasonably infer the Appellant's guilt. Consequently, the court affirms the convictions.