Tyler Stout Smith was convicted of vehicular homicide by recklessness and sentenced to four years in the Department of Correction, along with a $10,000 fine. On appeal, he raised three primary arguments: (1) the evidence did not sufficiently demonstrate recklessness, (2) his due process rights were violated when he was not allowed to present evidence regarding the victim's possible intoxication affecting her ability to avoid the collision, and (3) the trial court improperly increased his sentence from three years to four. The Court of Criminal Appeals of Tennessee affirmed the trial court's judgment.
The incident occurred on November 25, 2002, involving Lori Taylor, who was commuting on Highway 290. Taylor observed Smith driving aggressively, including rapid approaches and unsafe maneuvers, such as swerving into opposing traffic and attempting to pass her vehicle despite a double yellow line. Concerned for her safety and that of her children, she called 9-1-1 while closely monitoring Smith's actions, which included crossing into oncoming traffic multiple times.
Defendant's truck crossed into the westbound lane, resulting in a collision with Tammy D. Goodwin's red Saturn convertible, which led to her death. Witness Jennifer Salinge, a Tennessee Tech University Police Department employee, observed Defendant driving erratically, attempting to pass inappropriately, and was concerned enough to slow her vehicle for safety. She witnessed the accident, noting that over half of Defendant's truck was in the oncoming lane at the time of impact, which caused his truck to flip over after colliding with Goodwin's car. Another witness, Pam Holt, who was directly behind Goodwin, corroborated that Goodwin was not speeding and described how Defendant's truck struck Goodwin's car, causing it to spin out of control. Holt swerved to avoid the wreck and called 9-1-1.
Sgt. Mike Lee from the Cookeville Police Department investigated the scene, took photographs, and found no evidence of fault on the victim's part, concluding that Defendant's vehicle crossed into her lane. Trooper David Roark, an expert in accident reconstruction, confirmed that the collision was an opposite direction impact and that the evidence indicated Defendant was at fault. Officer Randy Brown, also from the Cookeville Police Department, noted the accident occurred during peak traffic hours as people were commuting to work and taking children to school.
Officer Brown confirmed that the accident took place in a location marked by double yellow lines. Upon arrival at the scene, he identified the Defendant as the truck driver, although the victim had already been removed. He collected statements from the Defendant and witnesses, including Ms. Taylor, Ms. Salinge, and Ms. Holt, whose accounts matched their trial testimonies. The Defendant cooperated but claimed not to remember the incident, stating he had looked down to change the radio and inadvertently crossed into oncoming traffic. He did not mention any need to brake or avoid another vehicle.
During the investigation, the Defendant disclosed a weekend trip to Tunica, Mississippi, where he consumed Oxycodone, Xanax, cocaine, and beer. Although he tested negative for drugs and alcohol in a blood test, the urine test revealed the presence of cocaine and its metabolite, along with Oxycodone and Dihydrocodeinone. The Defendant recounted leaving Tunica at 2:00 p.m. on Sunday and arriving home around 10:00 p.m. He stated he woke up at 6:20 a.m. on the accident day, and Officer Brown noted the weather was clear, with no signs of intoxication during questioning.
The victim, who died from multiple trauma due to the accident, was identified by her mother, Bonnie Smith, who confirmed the victim was driving her red Saturn convertible to drop off her sibling at school. The Defendant testified about his weekend, stating he had not planned to use drugs but acquired them from a local acquaintance. He last used drugs around 3:00 p.m. on Saturday, and after a long night, he slept until Sunday morning. He described being driven home by his mother after meeting his parents at a restaurant post-trip, with his father driving his truck. Both of the Defendant's parents testified during the trial about his history with drug abuse and prior rehabilitation efforts, expressing concern for their son's fatigue after the trip.
Both parents expressed concerns that the Defendant may have relapsed and used drugs during a trip prior to the accident. On the morning of November 25, Defendant claimed to have had breakfast and left for community service at 7:00 a.m. He asserted that any drugs used over the weekend did not impair his driving ability that morning. Although he admitted to attempting to pass Ms. Taylor and a slow-moving truck, he denied swerving while turning onto Gainesboro Grade and did not recall passing her in prohibited areas or the emergency lane. He also did not believe Ms. Taylor braked before the accident, asserting he was not driving recklessly.
Dr. Opless Walker, a pharmacy expert, testified that the drugs found in Defendant’s urine were not affecting his driving ability at the time of the accident. Walker noted that there was no evidence of drugs in Defendant's blood, which he argued indicated that the drugs could not have influenced his actions that morning.
In terms of legal proceedings, the Defendant contended that the evidence presented at trial was insufficient to prove recklessness beyond a reasonable doubt. The court's standard of review for such challenges requires examining the evidence in favor of the prosecution to determine if a rational trier of fact could establish the crime's essential elements. This applies regardless of whether the evidence is direct, circumstantial, or a combination of both. The credibility of witnesses and the weight of evidence are determined by the trier of fact, and the court does not re-evaluate evidence or substitute its inferences. The burden lies on the Defendant to demonstrate the insufficiency of the evidence against the presumption of guilt established by the verdict. Ultimately, the Defendant was convicted of vehicular homicide by recklessness.
Vehicular homicide is defined as the reckless killing of another person resulting from the operation of an automobile that creates a substantial risk of death or serious injury. 'Reckless' behavior involves consciously disregarding a significant and unjustifiable risk, which constitutes a gross deviation from the standard of care expected from an ordinary person. On November 25, 2002, the Defendant collided with a red Saturn convertible, resulting in the driver's death. Witnesses reported that the Defendant was driving erratically, swerving, and crossing into the victim's lane before the collision. One witness even attempted to call 9-1-1 due to concern over the Defendant's driving. The investigation corroborated these accounts and determined that the victim bore no fault in the incident. The Defendant claimed he momentarily looked away to adjust his car radio, arguing that this did not amount to recklessness. However, the jury found the evidence sufficient to support the prosecution's theory and accepted their account over the Defendant's.
Additionally, the Defendant contended that his due process rights were violated when he was prohibited from presenting evidence that the victim may have been under the influence of substances that hindered her ability to avoid the accident. The trial court granted the State's Motion in Limine to exclude this evidence. The Defendant's failure to include a transcript of the hearing on this motion in the appeal record led to a waiver of the issue, as he did not meet the burden of ensuring a sufficient record for meaningful review. Consequently, the court presumed the trial court's ruling was correct, and the Defendant was not entitled to relief on this matter.
Defendant challenges his four-year sentence for vehicular homicide by recklessness, a Class C felony, arguing he should have received the minimum sentence as a Range I, standard offender due to the absence of applicable enhancement factors. He contends that his prior driving offenses, including speeding tickets and improper turns, do not constitute criminal behavior. The court reviews the sentence de novo, presuming correctness if the trial court considered relevant sentencing principles and facts. The trial court found that Defendant had a history of criminal behavior, including four speeding tickets, an improper turn ticket, and involvement in a pretrial diversion program at the time of the accident. Additionally, Defendant admitted to drug use shortly before the incident and received two more tickets post-accident, which the court deemed significant. Although the trial court recognized Defendant's age as a mitigating factor, it did not weigh it heavily. The court concluded that it was justified in considering Defendant's driving history as criminal behavior and upheld the four-year sentence as consistent with sentencing principles and supported by the facts. The trial court's decision was affirmed, and Defendant was denied relief on this issue.
