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State of Tennessee v. Eric Boyd
Citation: Not availableDocket: E2019-02272-CCA-R3-CD
Court: Court of Criminal Appeals of Tennessee; November 30, 2021; Tennessee; State Appellate Court
Original Court Document: View Document
Eric Boyd was convicted of two counts of first-degree felony murder, two counts of aggravated robbery, two counts of especially aggravated kidnapping, and four counts of aggravated rape, receiving an effective sentence of two consecutive life sentences for the felony murder convictions and an additional 90 years for the other offenses. He appealed his convictions on several grounds: (1) denial of his motion for a change of venue or special jury venire, (2) the trial court's admission of federal court witness testimony transcripts as substantive evidence, (3) insufficiency of the evidence supporting his convictions, and (4) entitlement to relief under the cumulative error doctrine. The Court of Criminal Appeals of Tennessee affirmed the trial court's judgments, finding no errors in the trial proceedings. The case stems from the carjacking, robbery, kidnapping, rape, and murder of Channon Christian and Christopher Newsom in Knoxville, Tennessee, in January 2007. On the night of January 6, Ms. Christian planned to attend a party with Mr. Newsom but went missing. Their friends noted they were unresponsive to calls and texts after 10:00 p.m. Mr. Newsom's truck was found at the Washington Ridge Apartments, but Ms. Christian's vehicle was missing. Around 12:30 a.m. on January 7, a witness, Xavier Jenkins, reported seeing Ms. Christian's 4Runner near a house belonging to Lemaricus Davidson, with four men inside, which he found suspicious enough to report to his father. When Jenkins returned around 6:30 a.m., he saw the 4Runner again parked on Chipman Street. At 12:33 a.m. on Sunday, Ms. Christian informed her father she would be home between 2:00 and 3:00 a.m., with cell phone records placing the call near Davidson’s house. At 1:45 a.m., Jerome Arnold, a resident nearby, heard three gunshots from the direction of the railroad tracks. Later, at 7:45 a.m., Roy Thurman observed smoke rising from the tracks. By 12:20 p.m., a Norfolk Southern Railroad employee, J.D. Ford, found the burned body of Mr. Newsom near Davidson’s home, revealing he had been shot, bound, blindfolded, and partially clothed. On Sunday night, friends and family searched for Ms. Christian’s vehicle, locating it at Chipman and Glider Streets, where they noted the removal of several decals. Witness Sandra Kileen Bible stated she did not see the vehicle there at midnight on Saturday. Police found the vehicle's driver’s seat pushed back and mud in the backseat, with bags of clothing that Ms. Christian intended to donate missing. On January 9, police executed a search warrant at Davidson's home, where they discovered Ms. Christian’s body in a trash can and various items belonging to both victims, including clothing, personal belongings, and evidence such as a blue bandana and bleach cleaner. George Thomas testified that he stayed at Davidson's house in early January 2007 and recounted events leading up to the kidnapping, including Davidson's plans to steal a car. On January 6, after an argument with his girlfriend, Davidson was seen leading Ms. Christian into the living room, where both victims were found blindfolded and bound. Thomas described seeing a white SUV and recounted being instructed by Davidson to assist with Mr. Newsom, which he refused. Thomas provided testimony indicating that the Defendant forcefully took Mr. Newsom towards a drainage ditch after opening the back door of their vehicle. While Thomas remained in the front passenger seat, he observed three flashes and then saw the Defendant dragging Mr. Newsom's body behind a building. Following this, the Defendant retrieved gasoline and returned to the area where Mr. Newsom was left, after which Thomas witnessed a bright flash. The Defendant then drove back to Davidson’s house and stated, "that’s taken care of." Thomas informed Cobbins of the murder, but the Defendant insisted they stay while he completed his actions. The Defendant left in a white Pontiac, later returning 20 to 30 minutes later. During the following hours, Thomas, Cobbins, Coleman, Davidson, and the Defendant engaged in smoking marijuana, with Ms. Christian remaining in Davidson's bedroom. Thomas noted that he did not hear any distress from Ms. Christian. The next morning, the Defendant was absent, and Thomas had breakfast with Cobbins and Coleman. After a short outing, they returned to find the SUV missing. Subsequently, Daphne Sutton arrived and had a confrontation with Davidson, which led to her leaving the house. Thomas, Cobbins, and Coleman later stayed at a person named “Jody's” house and were driven by Jody to Kentucky the following Monday. Thomas recalled seeing the Defendant with a .22 caliber gun on Saturday but later corrected himself during cross-examination, stating he initially believed the Defendant had a revolver. He also disclosed having received a lighter sentence for his testimony. Jody Long testified about driving Thomas, Cobbins, and Coleman to Kentucky for drugs at the request of her drug dealer, Vince Wernimont. Upon her return, she learned of the police's search for them. Adrienne Mathis, the Defendant's cousin, confirmed ownership of the white Pontiac Sunbird used during the incident but could not recall specifics about loaning it to the Defendant or her previous testimony during trials related to Thomas or Coleman, despite attempts to refresh her memory with a transcript. Ms. Mathis expressed reluctance to testify at Defendant’s trial, acknowledging her previous testimony at a federal trial but failing to recall specific details, including a call from Defendant regarding her car or finding bullets in it. A transcript of her prior testimony was admitted into evidence. Xavier Jenkins identified Ms. Mathis’s white Pontiac Sunbird as the vehicle he saw parked near Davidson’s house on January 7. Police searched the car and found a gasoline container with a small amount of gasoline inside. Daphne Sutton testified about moving out of Davidson’s residence in December 2006, leaving behind only minimal furniture. After an altercation with Davidson, she suspected he had another woman in the house when he asked her to wait before coming over to retrieve a bag of clothes. Upon arrival, she encountered Thomas and Cobbins and was physically prevented from accessing the bathroom. Sutton observed unusual arrangements in the bedroom and noted that Davidson attempted to give her money along with used clothes. On January 8, Davidson called Sutton for a ride, revealing that Cobbins had the key to his locked house. Sutton picked him up, and he stayed with her that night. The following day, after learning of a body found in Davidson’s house, Sutton drove him to Ridgebrook Apartments. Danielle Lightfoot testified that on January 9, Defendant and Davidson stayed at her apartment, where they asked to remain until evening despite knowing a photograph of Davidson was on the news. On January 11, police apprehended Defendant at Ridgebrook Apartments, where he cooperated and led them to Davidson. They discovered Davidson at a vacant house, where a SWAT team arrested him and found a .22 caliber revolver and Nike shoes belonging to Mr. Newsom. On January 11, Thomas, Cobbins, and Coleman were arrested at Natosha Hays’s residence in Lebanon, Kentucky. A search revealed a .22 caliber Clerke revolver and personal items belonging to Ms. Christian. Ballistics linked two .22 long rifle bullets recovered from Mr. Newsom’s body to this gun, although a third bullet was too damaged for identification. Autopsies by Dr. Darinka Mileusnic-Polchan indicated that Mr. Newsom suffered severe trauma, including anal penetration shortly before death, and was shot three times, with the fatal shot causing instantaneous death. His body was subsequently set on fire with gasoline. Ms. Christian died from asphyxiation, having been stuffed into a trash can with a plastic bag over her head. She sustained extensive injuries, including bruising and lacerations, indicative of sexual assault, and her death occurred shortly after the bag was applied. DNA evidence identified Davidson’s and Cobbins’ sperm in connection with Ms. Christian, along with Davidson’s fingerprints on garbage bags containing her body. Additionally, Davidson's DNA was found on a gun holster in Ms. Mathis’s car, but neither he nor Thomas had DNA linked to items from the Chipman Street house. Defendant was convicted of multiple serious offenses, including 16 counts of felony murder, two counts of first-degree premeditated murder, two counts of aggravated robbery, four counts of especially aggravated kidnapping, and 12 counts of aggravated rape. The trial court merged these convictions into two counts of felony murder, two counts of aggravated robbery, two counts of especially aggravated kidnapping, and four counts of aggravated rape, resulting in an effective sentence of two consecutive life sentences plus an additional 90 years. Defendant did not appeal the sentencing but filed a timely motion for a new trial, which was denied. In his appeal, Defendant raises four main issues: 1. The trial court erred in denying his motion for a change of venue or, alternatively, a special jury venire due to extensive pre-trial publicity. 2. The trial court improperly allowed the introduction of transcripts from a prior federal trial as substantive evidence. 3. The evidence was insufficient to support the convictions. 4. He is entitled to relief under the cumulative error doctrine. Regarding the change of venue, Defendant's motion argued that pre-trial publicity would prevent a fair trial. The trial court, however, found that the age of the case and the nature of the publicity—largely not focused on Defendant—supported the decision to deny the motion. The court noted that there was a greater likelihood of finding an impartial jury in the present time compared to when the crimes occurred. Defendant contends that members of the jury venire had preconceived notions about his guilt, but the State argues that he has not demonstrated actual prejudice. The decision to grant a change of venue lies in the trial court's discretion, as outlined under Tennessee Rule of Criminal Procedure 21(a). The criteria for determining whether a change of venue is warranted, as established in Rogers, include: the nature, extent, and timing of pretrial publicity; whether the publicity is fair or inflammatory; its content; the pervasiveness of the publicity in the venire area; circulation beyond that area; the time elapsed since the publicity; the jury selection process; jurors' familiarity with the publicity; the use of peremptory challenges; involvement of police or prosecution in the publicity; the severity of the offense; any threats or hostility towards the defendant; the size of the venire area; and related testimonies. To succeed in a motion for change of venue, a defendant must prove that the seated jurors were biased or prejudiced against them, as mere exposure to pretrial publicity is insufficient for a venue change. Prejudice is not presumed from extensive publicity alone, and jurors need not be completely unaware of case facts to be qualified. The trial court's jury selection process was thorough, involving individual voir dire and the excusal of 15 jurors for cause based on impartiality concerns. Both parties had 12 peremptory challenges, but only eight were exercised. The defendant did not assert bias among the 12 jurors who served but noted that many in the jury pool had prior knowledge of the victims and case details. Defendant argues that prospective jurors in Knox County could not provide a fair trial due to their questionnaire responses. The trial court evaluated multiple relevant factors and engaged in an extensive voir dire process to assess jurors' exposure to media coverage regarding the case. Jurors who indicated potential bias were excused. The Defendant failed to demonstrate any actual prejudice or bias among the selected jurors, as evidenced by the questionnaires and voir dire transcripts. Additionally, the Defendant did not exhaust all peremptory challenges, which has previously been cited as a factor in denying change of venue requests. The trial court exercised significant care in the jury selection process, concluding that the Defendant received a fair trial in Knox County. Regarding the admission of prior testimony from Adrienne Mathis, the Defendant contends that it should have been excluded due to lack of trustworthiness under Tennessee Rule of Evidence 803(26). Ms. Mathis testified during a jury-out hearing, expressing a lack of memory about her previous testimony and suggesting it was not truthful. The trial court determined that she did not outright deny her earlier statements and ruled the transcripts of her prior testimony inadmissible as extrinsic evidence. Ultimately, the trial court did not err in either denying the change of venue or admitting the prior testimony. The State sought to introduce Ms. Mathis's prior testimony as substantive evidence under Tennessee Rule of Evidence 803(26), citing inconsistencies with her current statements regarding loaning her car to the Defendant and finding bullets in it. The State highlighted that Ms. Mathis had been cross-examined and that her prior testimony was given under oath and aligned with her statements in other trials involving co-defendants, which suggested trustworthiness. The trial court recognized that Ms. Mathis had testified at the Defendant's federal trial, deemed her previous testimony a written statement made under oath, and found her answers during that testimony to be coherent and cooperative. Consequently, the court ruled that her prior statements were trustworthy and allowed their introduction as substantive evidence. The admissibility of evidence is generally reviewed for abuse of discretion, which occurs if the trial court misapplies legal standards, reaches illogical conclusions, or makes erroneous assessments of evidence. The parties acknowledged that the prior testimony constituted hearsay, typically inadmissible unless it falls under specific exceptions outlined in Rules 803 and 804. Rule 803(26) allows for the admission of a witness's prior inconsistent statements as substantive evidence if the witness testifies at trial, the statement is recorded or written and signed, and a pretrial hearing confirms trustworthiness. Rule 613(b) further stipulates that a witness must be given the opportunity to address any inconsistent statements before extrinsic evidence is admitted. The 2009 Advisory Commission Comment clarifies that this rule was established to address situations where witnesses may feign memory loss due to external pressures, ensuring the reliability and authenticity of prior statements. For a statement to qualify as substantive evidence, it must adhere to the admissibility conditions outlined in Rule 613, which specifically addresses prior inconsistent statements, excluding consistent statements. The defendant argues that Ms. Mathis's earlier testimony lacks the trustworthiness necessary under Rule 803(26), citing her admission that she merely repeated information from documents, received pre-testimony preparation, and suggested her prior testimony may not have been truthful. The court disagrees, referencing a prior ruling that a witness's inability to remember events renders their previous statement inconsistent with trial testimony. Ms. Mathis had the chance to clarify her prior statements and was cross-examined, which fulfilled Rule 613's requirements. The trial court found the earlier statements trustworthy, leading to the conclusion that the court did not err in admitting this testimony as substantive evidence. Regarding the sufficiency of the evidence, the defendant contends that the trial court wrongly upheld the jury's verdict, claiming insufficient evidence to support his convictions, which he believes relied solely on an accomplice's uncorroborated testimony and lacked proof of requisite intent for conviction. In contrast, the State argues that the evidence was adequate. The review standard for evidence sufficiency demands that the evidence be evaluated in the light most favorable to the State, allowing for all reasonable inferences. The key question is whether a rational juror could find the essential elements of the crime beyond a reasonable doubt. The defendant bears the appellate burden to demonstrate that the evidence was insufficient to sustain the guilty verdict. The convictions for first-degree felony murder, aggravated robbery, especially aggravated kidnapping, and aggravated rape hinge on the intent to commit the underlying felony, as defined under Tennessee law. A defendant involved in a scheme to commit certain felonies is liable for any resulting death, qualifying for felony murder charges regardless of the identity of the actual killer or prior contemplation of the murder. Relevant felonies include aggravated robbery, defined as robbery with a deadly weapon or causing serious bodily injury; robbery, characterized by intentional theft through violence or fear; especially aggravated kidnapping, which involves unlawful confinement with a deadly weapon or serious injury; and aggravated rape, which involves unlawful sexual penetration using force or coercion, while armed or causing bodily injury. Criminal responsibility can be established if a person promotes, assists, or benefits from the commission of an offense by another, irrespective of whether they physically participated in the crime. The presence and companionship with the perpetrator before and after the crime can imply participation. Evidence presented showed the defendant was part of a group that returned to a residence with the victims, who were restrained. The defendant was present during the rapes of both victims and later led one victim to a location where he was shot and his body burned. Testimony indicated the defendant was aware of and involved in the actions leading to the victim's death, asserting his role in the criminal activities. Defendant spent several hours in Davidson's house, aware that Ms. Christian was confined and being raped in a bedroom. After the murders, Defendant and Davidson went to Danielle Lightfoot’s apartment for the night, despite Davidson's photograph being broadcasted on local news. They later broke into and hid in a vacant house. The jury could infer that Defendant intended to support the commission of the offenses for which he was convicted. Under Tennessee law, a conviction cannot rely solely on uncorroborated accomplice testimony. An "accomplice" is defined as someone who knowingly and voluntarily participates in a crime alongside a principal. George Thomas was acknowledged as an accomplice since he faced similar charges as the Defendant. While uncorroborated testimony is insufficient for conviction, corroborative evidence—whether direct or circumstantial—must connect the defendant to the crime. This evidence does not need to be overwhelming but should reasonably imply the defendant's involvement and identity. The jury has the discretion to determine the adequacy of this corroboration. The court concluded that sufficient evidence existed to corroborate Thomas's testimony implicating Defendant in the crimes. Thomas testified that the Defendant drove a white Pontiac and was involved in bringing the victims to Davidson’s house. The State supported this with Ms. Mathis’s prior testimony, stating the Defendant borrowed her white Pontiac Sunbird that weekend. DNA belonging to the Defendant was found on a gun holster in Ms. Mathis’s vehicle. Xavier Jenkins identified Ms. Mathis’s car parked behind a Toyota 4Runner outside Davidson’s house during the carjacking. Thomas also claimed he was with the Defendant when they transported Mr. Newsom, who was bound and gagged, to the railroad tracks, where the Defendant shot him three times and set his body on fire. Thomas reported seeing flashes during the shooting, corroborated by Jerome Arnold, who heard gunshots at 1:45 a.m., and forensic evidence confirmed Mr. Newsom was shot thrice and found burned and bound without shoes. Thomas stated the Defendant retrieved a gasoline can after the shooting, which was supported by forensic evidence showing gasoline on Mr. Newsom’s body. Ms. Mathis testified to keeping gas cans in her car, and police found a nearly empty can in the vehicle loaned to the Defendant. The jury found sufficient corroboration of Thomas’s testimony, and independent evidence linked the Defendant to the offenses, affirming the trial court's judgment. The Defendant claimed cumulative errors deprived him of a fair trial; however, no individual errors were established, rendering the cumulative error doctrine inapplicable. The trial court’s judgments were ultimately affirmed.