State of Tennessee v. William Ingram

Citation: Not availableDocket: W2017-02343-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; December 13, 2018; Tennessee; State Appellate Court

Original Court Document: View Document

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William Ingram was convicted of aggravated assault by a Shelby County jury and sentenced to six years in the Shelby County workhouse, following an incident on August 15, 2015, involving the victim, Kerry Soule. The Shelby County Grand Jury indicted Ingram on charges of especially aggravated kidnapping, aggravated assault inflicting serious bodily injury, and theft of property valued between $1,000 and $10,000. The relationship between Ingram and Soule was rekindled via Facebook, leading to an intimate relationship prior to the incident.

On the day of the event, after spending time together at Soule’s home and then at a bar called Bubba's, an argument ensued when Ingram perceived embarrassment from a comment regarding another woman in the bar. Following this, an escalation of tension led to Ingram yelling at Soule. Despite the argument, Soule attempted to reconcile by inviting Ingram into her car, where she took the passenger seat, indicating her desire to resolve the conflict and continue their time together. The appellate court affirmed the trial court's judgment regarding the sufficiency of evidence for the conviction.

The victim and the Appellant left Bubba’s bar around 6:00-6:30 p.m. after being there for about 1 to 1.5 hours. In the parking lot, the Appellant began to physically assault the victim, hitting her multiple times in the face and threatening her life, stating, "I’m going to kill you." Despite the assault, she felt unable to escape due to the busy road. After driving for about 10-15 minutes, they arrived at the Appellant's father's house, where the victim attempted to seek help from a neighbor but was unsuccessful. The Appellant attacked her again, dragging her across the yard until a nearby neighbor intervened by threatening to call the police, causing the Appellant to flee in the victim's car.

The victim suffered severe injuries, including a subdural hematoma and visible bruises, requiring hospitalization and an airlift to a neurosurgeon. She spent four days in the hospital, primarily in the ICU. While the Appellant was in jail, he wrote a letter to the victim acknowledging the incident and making further threats against her family. A firefighter, Vance Culver, witnessed the aftermath, noting the victim's distress as she sought help from a neighbor while the Appellant attempted to access the garage of a nearby house. Culver could hear the victim banging on the door, indicating her desperate situation.

The Appellant was observed dragging the victim across a yard by her hair shortly before fleeing in a red car. Witness Culver, who estimated the incident lasted between thirty to sixty seconds, described the victim as shocked and disoriented, with visible bruising and swelling on her face. After calling the police, he remained with the victim until their arrival two minutes later, providing a statement afterward. Culver noted he had seen the Appellant at the residence previously, which he deemed a "flop house," and mentioned he did not recognize the victim. Initially, he speculated that the victim and Appellant were simply retrieving mail until the victim banged on a neighbor's door for help.

Upon arrival, Officer Knight found the victim visibly upset and injured. He briefly spoke with her before she was taken to the hospital, where he later documented her injuries with photographs. Officer Knight clarified that while the victim was shaken, she was not completely disoriented.

Dr. Daniel Hoit, a neurosurgeon, examined the victim and discovered a subdural hematoma through a CAT scan, indicating bleeding between the brain and skull; this condition can lead to serious complications resembling a stroke. Although not always life-threatening, Dr. Hoit noted its potential severity and recommended ICU observation. At the time of examination, the victim was stable, awake, and responsive, with no severe symptoms apart from mild headaches. She was discharged two days later with a diagnosis of stable traumatic subdural hematoma, although Dr. Hoit emphasized the seriousness of the condition, regardless of the victim's apparent clarity.

The Appellant was acquitted of especially aggravated kidnapping and theft but convicted of aggravated assault, a Class C felony, and sentenced to six years as a Range I standard offender. On appeal, the Appellant challenges the sufficiency of the evidence supporting the aggravated assault conviction, asserting that the State did not prove the victim suffered serious bodily injury. The appellate standard requires the Appellant to demonstrate that no reasonable jury could have found the essential elements of the offense beyond a reasonable doubt, shifting the burden of proof following a conviction. The evidence presented at trial indicated that the Appellant physically assaulted the victim, causing significant injury, including a subdural hematoma, which necessitated hospitalization. Aggravated assault requires intentional or knowing conduct that results in serious bodily injury. Serious bodily injury is defined by specific criteria, including a substantial risk of death or protracted unconsciousness. The distinction between bodily injury and serious bodily injury is typically a factual determination for the jury. The Appellant’s argument centers on the claim that the evidence did not sufficiently establish the serious nature of the victim's injuries as required by the indictment.

The Appellant argues that the evidence did not demonstrate that the victim experienced protracted unconsciousness, extreme physical pain, significant disfigurement, or substantial impairment of bodily functions as defined under Tenn. Code Ann. 39-11-106(a)(34)(B) and (E). Consequently, the Appellant claims the State failed to prove that the victim's injuries posed a "substantial risk of death," as required by Tenn. Code Ann. 39-11-106(a)(34)(A) to establish serious bodily injury. The State counters that it sufficiently proved aggravated assault by showing the victim endured extreme physical pain and that her injuries presented a substantial risk of death. However, the record indicates that the victim was never asked directly about experiencing extreme physical pain, nor did she explicitly state such during her testimony. The State concedes that the victim did not use the term "extreme physical pain" but argues that other evidence, including witness testimonies and photographs, allowed the jury to infer this pain.

The court referenced previous cases, including State v. Sims, which utilized the ejusdem generis principle to interpret "serious bodily injury," indicating that pain must be comparable to injuries involving substantial risk of death or significant impairment to be considered extreme. The court noted the challenges in quantifying pain, emphasizing that its subjective nature is a factual question for the jury. In State v. Farmer, the Tennessee Supreme Court found that the evidence did not support a finding of serious bodily injury due to the victim’s mild to moderate pain following a gunshot wound, suggesting that the jury could not reasonably infer extreme pain from the provided testimony and medical records.

The evidence presented established that the Appellant repeatedly struck the victim in the head and dragged her by her hair, resulting in visible facial injuries. A responding officer observed the victim was upset and in pain, and although a doctor testified about a subdural hematoma, no specific details regarding associated pain were provided. The State submitted photographs depicting extensive bruising but did not present medical records. 

Despite the absence of expert testimony directly linking the victim's injuries to a substantial risk of death, the court referenced a previous ruling (Farmer) that emphasized focusing on the actual injury rather than potential outcomes. The Appellant contended that the victim's condition was not life-threatening, while the State argued that the doctor's assessment of the hematoma as dangerous was sufficient proof of serious bodily injury. 

The court concluded that expert testimony is often necessary to determine the risk of death associated with injuries. Dr. Hoit’s testimony regarding the hematoma's life-threatening nature and the recommended ICU observation supported the finding of serious bodily injury, affirming the Appellant’s aggravated assault conviction. The trial court's judgment was upheld.