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State of Tennessee v. Susan Lynette Baker
Citation: Not availableDocket: M2016-00434-CCA-R3-CD
Court: Court of Criminal Appeals of Tennessee; July 31, 2017; Tennessee; State Appellate Court
Original Court Document: View Document
Susan Lynette Baker appeals her convictions for felony murder, especially aggravated robbery, and setting fire to personal property, stemming from the death of Clifford Carden, Jr. and the theft of his belongings. Baker argues that the trial court improperly refused to suppress her pretrial statement, evidence of her theft, and motel surveillance video; denied her motion to sever the arson charge; found insufficient evidence to support her convictions; and that the felony murder statute violates due process principles. The court affirms the lower court's judgments. The case details include the discovery of Carden's body in a river and a burned car linked to the crime. An autopsy revealed he died from a gunshot wound to the head, with evidence suggesting the gun was fired from a close range. Detective Lockhart identified Carden through a placard found in the car and noted that items, including NASCAR memorabilia, were missing from his home after a visit with his estranged wife. Surveillance footage showed Baker and co-defendant Thomas Brian Bettis arriving at a motel in Carden's car, with Baker carrying stolen items. Bettis was later seen with singed facial hair and possible blood on his jeans. Randy Griffith provided a ride to the defendant and co-defendant on February 2, 2011, to a Walmart where they were seen shopping and making a cash purchase over $300 shortly after 7:00 p.m. Items found in a dumpster, including a pill bottle belonging to the victim and blood, raised suspicion. The defendant sold a nine millimeter handgun to bar owner Gary Harding, which was later confirmed to be the murder weapon used against the victim. The defendant was arrested on February 8, 2011, after being advised of her rights and providing a video-recorded statement to TBI agents. In her statement, the defendant revealed past romantic relationships with both the victim and co-defendant. Following a falling out with the victim, they met for dinner and drinks before the murder. The defendant admitted to planning to rob the victim and claimed that he became aggressive, prompting her to shoot him. Afterward, she and the co-defendant moved the victim's body and disposed of it in a river, taking over $1,000 from him and stealing items from his home. They returned to the motel and planned to burn the victim's car after obtaining gasoline. Testimony indicated the defendant was addicted to prescription medications and had a history of mental illness, which was corroborated by a neuropsychologist who noted her cognitive deficits. The jury ultimately convicted the defendant based on this evidence. A life imprisonment sentence was imposed on the defendant for murder, along with concurrent sentences of 15 years for especially aggravated robbery and 2 years for setting fire to personal property. After her motion for a new trial was denied, the defendant filed a notice of appeal. In the appeal, she contested the trial court's decisions to deny her motions to suppress her statement to law enforcement, evidence of items stolen from the victim’s residence, and surveillance video from a hotel. She also challenged the trial court's refusal to sever the arson charge from the other felony charges, claimed insufficient evidence for her convictions of felony murder and especially aggravated robbery, and argued that Code section 39-13-202 violates due process for lacking a mens rea requirement for felony murder. Regarding her statement to Agent Wilson and Detective Lockhart, the defendant argued it was not given voluntarily, citing neurocognitive deficits and voluntary intoxication from medication that impaired her understanding of her rights. During the suppression hearing, Agent Wilson testified that he provided Miranda warnings to the defendant twice, noting that she did not request an attorney and appeared lucid throughout the interview. He stated that she asked questions about her rights before signing the waiver, demonstrated clear recall of the crime details, and did not show signs of intoxication. Agent Wilson assessed that the defendant was of sound mind during their interaction and provided coherent and specific responses. The video recording of the defendant's statement was accepted as evidence and analyzed by the trial court. During cross-examination, Agent Wilson stated he did not perceive the defendant as impaired during the interview and could not explain the booking sheet's indication of her being under the influence. He did not consider delaying the questioning until the next day. Initially, the defendant claimed the co-defendant killed the victim but later confessed to shooting him. Wilson interpreted the defendant's initial denial as an indication of her competence to deceitfully misrepresent facts. He noted that despite identifying himself as a TBI agent, the defendant questioned if he was a lawyer at the end of the interview, indicating confusion about her rights. Detective Lockhart testified that he believed the defendant was not under the influence during her arrest, having no prior knowledge of her drug history, and found her behavior consistent and coherent throughout the interrogation. He denied observing any slow or subdued demeanor from the defendant. Incarcerated together for three weeks, Ashley Hickey testified that the defendant confided details about the murder and her strategy to evade trial competency. Hickey described the defendant's fluctuating moods and a medical incident involving self-harm. She acknowledged having a prior conviction for filing a false police report and denied any personal connection to the co-defendant despite previous interactions. The defendant's father, Raymond White, detailed her long-standing pain medication addiction beginning at age 10, which he claimed impaired her memory. He recounted a conversation with Sheriff Hitchcock, who described the defendant's condition as "bad shape" and "stoned" at the time of her arrest, though White did not see her that day. Corrections Officer Stacy Slaven testified about her role in booking the defendant, noting that the defendant appeared very tired and was falling asleep during the process. Slaven recognized that the booking sheet indicated the defendant was likely under the influence of drugs. Deputy Chief Clint Walker, who was not present during the booking but observed the defendant the next day, reported that she was placed in a medical cell to monitor her closely due to concerns about potential self-harm related to her serious charges. He noted that she slept extensively for three days, despite being in a busy environment with constant activity, and showed no signs of drug withdrawal. Doctor Brown began treating the defendant post-arrest, following a diagnosis of schizoaffective disorder, bipolar type, with psychotic features. However, he found no evidence of schizophrenia consistent with that diagnosis; instead, he identified neurocognitive deficits likely due to a brain malformation. Brown observed notable differences in the defendant's behavior during her police interrogation, including emotional instability (lability) and disinhibition, along with possible slurred speech, leading him to suspect she was under the influence of a psychoactive substance. At the request of the defendant’s attorney, Doctor Brown assessed her understanding of her rights using two assessment tools, finding significant difficulties across eight sessions. However, he conceded that nothing in the defendant's demeanor during the video interrogation would have indicated to the interviewing officers that she lacked the capacity to comprehend or voluntarily waive her Miranda rights, as they had no observable signs to suggest any incapacity. Doctor Brown assessed the defendant's personality as one that would likely lead her to acquiesce to police demands to avoid conflict, although he noted he did not strongly perceive this during the interrogation video. He indicated that the defendant would adapt her responses to align with what she believed the officers wanted to hear and maintained that she was not malingering but rather had poor working memory. Despite believing the defendant voluntarily made her statements, he acknowledged that she lacked comprehension regarding the implications of cooperating with law enforcement. During cross-examination, he conceded that he observed no signs of significant impairment affecting her ability to waive her rights or provide a statement, stating that her mental issues were subtle enough that he did not identify them even after extensive psychotherapy and multiple viewings of the interrogation footage. The trial court ultimately denied the motion to suppress the defendant's statement, ruling that the state's actions in obtaining the information were fair and that it was not the officers' responsibility to act as mental health evaluators. The court emphasized the importance of the totality of circumstances in determining the admissibility of statements. Appellate review will uphold the trial court's factual findings unless the evidence significantly contradicts them, while legal applications are reviewed de novo. The Fifth Amendment protects individuals from being compelled to testify against themselves, requiring that confessions be voluntary and not coerced through threats, promises, or improper influences. Confessions obtained during custodial interrogations are subject to the same legal standards as those obtained prior to custody, provided proper Miranda warnings are given. Courts assess the voluntariness of confessions by examining the totality of circumstances, focusing on whether law enforcement's conduct overbears the defendant's will to resist, regardless of the truthfulness of the confession. Under Article I, section 9 of the Tennessee Constitution, the voluntariness standard is broader and more protective than that under the Fifth Amendment. For a waiver of rights to be valid, the defendant must understand the nature of the rights and the consequences of waiving them. Courts require evidence of an uncoerced choice and comprehension of rights for a valid waiver. Factors influencing a defendant's competency to waive rights include age, background, cognitive abilities, prior criminal experience, demeanor, and clarity of the Miranda warnings. Mental impairments are considered alongside other factors, with no single element, such as IQ, being determinative of a person's ability to knowingly waive constitutional protections. The trial court's denial of the motion to suppress was upheld, as the defendant, despite Dr. Brown's testimony regarding her neurocognitive deficits, voluntarily waived her constitutional rights and provided a statement. Dr. Brown confirmed that she comprehended her rights, having received Miranda warnings twice and signed a written waiver. A review of the video recording indicated that the defendant was lucid and coherent, engaging with officers and later admitting her involvement in the shooting, including a detailed account and a physical demonstration. There was no evidence of coercion by the officers. Regarding the evidence of theft from the victim’s residence, the defendant argued for its exclusion based on relevance and potential unfair prejudice. However, the trial court indicated it had ruled on this motion prior to trial, but the ruling was not documented in the appeal record. Consequently, the defendant did not substantiate her appeal with proper arguments or references, resulting in a waiver of her claims according to Tennessee appellate rules. The defendant contends that the trial court improperly admitted video surveillance from the Mountain Valley Inn and Suites, claiming the accelerated speed of the recording was prejudicial as it obscured evidence of the defendant's alleged impairment. The State argues that the admission was appropriate, noting that the defendant had previously sought to exclude the video on grounds of its speed, but the court did not document its ruling on this motion. During the trial, the defendant's objection to the video was overruled after the court referenced prior discussions about it, and the judge instructed the jury that the video played faster than real-time to avoid confusion regarding the depicted actions. The admissibility of evidence is within the trial court's discretion, and appellate courts will not interfere unless there is a clear abuse of discretion evident in the record. An abuse of discretion occurs when a court applies an incorrect legal standard or reaches an illogical conclusion that results in unjust harm to a party. Relevant evidence is defined as having the potential to affect the likelihood of a consequential fact in the case, while irrelevant evidence is inadmissible. Even relevant evidence may be excluded if it is more prejudicial than probative or if it causes confusion or undue delay. In this instance, the surveillance video depicted the defendant and a co-defendant arriving in the victim’s vehicle and carrying items from the victim's home into the motel, along with the defendant paying for their room with cash presumably taken from the victim. Therefore, the video was deemed relevant to the charges. The trial court’s instruction to the jury mitigated any potential prejudice from the video’s speed. Additionally, the defendant argues that the trial court erred in denying the request to sever the charge of setting fire to personal property from the charges of felony murder and especially aggravated robbery. The defendant argues for severance of charges, claiming that her involvement in the burning of the victim's car was minor compared to the more serious charges and that the co-defendant was primarily responsible. She asserts that without severance, she risks being unfairly judged for the more serious offenses due to her limited role. However, she does not provide legal authority to support her claim. The review of a trial court's decision on consolidating or severing charges is conducted for abuse of discretion, which occurs if the court applies incorrect legal standards, reaches illogical conclusions, or bases its ruling on erroneous assessments of proof. A hearing is required before denying a severance request. The court must resolve issues of joining or separating offenses before trial, as outlined in Tennessee Rule of Criminal Procedure 13(b). The rules stipulate that offenses must be joined if they stem from the same conduct or criminal episode, and the defendant can move for severance before trial according to Rule 14. During her severance motion hearing, no proof was presented, and the State argued for mandatory joinder, which the trial court accepted. The rules for joinder are governed by Tennessee Rule of Criminal Procedure 8, which defines both mandatory and permissive joinder. Although the defendant acknowledges that the offenses were mandatorily joined, she maintains that severance is necessary for a fair determination of her guilt. The court disagrees, noting that evidence regarding the burning of the victim's car is relevant to the defendants' attempt to conceal their involvement in the murder and robbery. Evidence indicated that the co-defendant was primarily responsible for the burning offense, but the defendant remained criminally liable for the actions taken during the commission of the crime, as outlined in T.C.A. 39-11-402(a)(2). The defendant contested the sufficiency of the evidence supporting her felony murder conviction, arguing that the State failed to prove she murdered the victim during the robbery. She also claimed insufficient evidence for her especially aggravated robbery conviction, asserting that the robbery could not have involved violence or a deadly weapon since the victim was deceased when she took his money and car. The State maintained that sufficient evidence existed. The court reviews claims of insufficient evidence by considering whether a rational trier of fact could find the essential elements of the crime beyond a reasonable doubt, based on the evidence presented in favor of the prosecution. The court emphasized that it would not re-weigh evidence or reassess witness credibility, and must view the evidence in the strongest light for the State. Especially aggravated robbery, as defined in T.C.A. 39-13-403, involves robbery with a deadly weapon or serious bodily injury to the victim. The defendant's argument that one cannot rob a dead person was countered by evidence that she and the co-defendant had planned to rob the victim while she was armed. The defendant was convicted of aggravated robbery after shooting the victim and taking his money. The court addressed the defendant's argument that the State did not prove she intended to rob the victim before or during the killing. Under Tennessee law, felony murder involves a killing committed in the course of committing or attempting to commit a robbery. The intent required for felony murder focuses on the underlying felony, not the intent to kill. Jurors must determine if the defendant had the intent to commit robbery based on the circumstances surrounding the events. The court referenced previous cases establishing that a killing can be considered part of the felony if there is a connection in time, place, and continuity of action. Evidence indicated that the defendant and her co-defendant planned to rob the victim, who was known to carry drugs and cash. The defendant armed herself before meeting the victim and admitted to taking his money immediately after the killing, which the jury could interpret as not merely an afterthought. The defendant also contended that the felony murder statute violated due process by not requiring an intent to kill. However, the court upheld prior rulings rejecting this claim. Ultimately, the court affirmed the trial court's judgment.