State of Tennessee v. Timothy John McKnight, Jr.

Citation: Not availableDocket: M2015-02306-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; September 19, 2016; Tennessee; State Appellate Court

Original Court Document: View Document

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Timothy John McKnight, Jr. appeals his aggravated robbery conviction, asserting insufficient evidence and trial court error in limiting cross-examination of two witnesses. The Tennessee Court of Criminal Appeals reviewed the case and affirmed the trial court's judgment. 

Procedurally, McKnight and co-defendant Melvin Jackson, Jr. were indicted on aggravated robbery charges, with their trials severed. McKnight was convicted of aggravated robbery and sentenced to eight years, while he was acquitted of attempted aggravated robbery. In December 2009, he sought post-conviction relief, claiming ineffective assistance of counsel for failure to file a motion for a new trial and notice of appeal. In January 2015, the post-conviction court allowed McKnight to file a delayed motion for a new trial, which was ultimately denied, leading to this appeal.

Factual evidence presented at trial indicated that on January 26, 2007, while working at Jack’s Discount Tobacco, employees Shelly Buskell and Samir Mikhael were confronted by a man brandishing a gun who announced a robbery. Buskell recognized the man as a regular customer but did not know his name. She informed Mikhael of the robbery and handed over the cash from her register to the gunman, who then threatened Mikhael as well. The incidents were corroborated by both victims, who had previously seen McKnight and the gunman together in the store.

The gunman entered the store and stole money from the cash register while Defendant allegedly served as a lookout. Witness Ms. Buskell, focused on the gun, did not notice Defendant's actions, while Mr. Mikhael testified that Defendant stood by the door, held it open for the gunman, and did not show any surprise during the robbery. Video surveillance confirmed Mr. Mikhael's account, showing Defendant opening the door and leaving shortly before the gunman exited. During an interview, Defendant initially denied involvement, claiming he was instructed to hold the door and ran off, but later admitted to knowing the gunman, Mr. Jackson, and that they had planned the robbery together. Defendant stated his role was to ensure no customers were present and to hold the door, with an agreement to split the stolen money, reported to exceed $600. A police search of Defendant’s home revealed cash, a gun, and bandanas, though the recovered amount did not match the theft. Mr. Jackson testified that he and Defendant had discussed the robbery plan at Defendant’s house, where Defendant was present during the planning stages, and observed a gun in Jackson's possession. Initially, Defendant did not believe Jackson would carry out the robbery after multiple failed attempts to do so. At the time of arrest, Defendant was seventeen years old and in the eleventh grade.

Defendant initially perceived Mr. Jackson's actions as mere bravado before both men entered the store. Inside, while Defendant was making a purchase, Mr. Jackson entered with a gun, ordered Defendant to hold the door open, and then Defendant fled, claiming he did not want to be involved. He denied knowledge of Jackson's intention to commit robbery. 

Defendant contests the sufficiency of the evidence linking him to the robbery and argues that the trial court improperly restricted his cross-examination of two witnesses. The court's review of evidence sufficiency follows established principles: it considers whether a rational jury could find the defendant guilty beyond a reasonable doubt, placing the burden on the defendant to demonstrate insufficiency. The prosecution is granted the benefit of the strongest legitimate view of the evidence and any reasonable inferences. The jury's role includes assessing witness credibility and resolving evidence conflicts, with a guilty verdict affirming the State's witnesses and theory. 

Aggravated robbery, defined under Tennessee law, involves intentional or knowing theft through violence or intimidation, with a deadly weapon or an item perceived as such. Criminal responsibility under T.C.A. § 39-11-402(2) holds an individual accountable for another's crime if they intentionally assist in its commission. This principle, explained in State v. Dickson, frames criminal responsibility as a means to establish guilt based on another's actions, rooted in aiding and abetting theories.

Criminal responsibility does not require a defendant to have physically participated in a crime; they can be held as principal offenders if convicted under this theory. In this case, the defendant argued he was unaware of a robbery being planned and only participated under duress from an accomplice, Mr. Jackson. However, evidence indicated the defendant admitted to a prearranged plan to rob the store, intending to act as a lookout. Testimony and surveillance footage showed the defendant holding the door while the robbery occurred, leading the jury to reasonably conclude he was a willing participant, thus supporting his conviction for aggravated robbery.

Additionally, the defendant contended that the trial court limited his counsel's cross-examination of witnesses, claiming it infringed on his right to a fair trial. The trial court maintained discretion over cross-examination scope, and objections were upheld when questions were deemed speculative or redundant. Specifically, objections to questions posed to witness Ms. Buskell were justified since she had already stated she could not see the defendant’s actions during the incident. Likewise, objections regarding Detective Steele's prior interviews were not an abuse of discretion as the information had been sufficiently covered. Ultimately, the trial court's judgment was affirmed.