Supreme Court Affirms Convictions For 2010 Robbery And Home Invasion In Knoxville

  • Tuesday, May 5, 2015

The Tennessee Supreme Court has affirmed the convictions of three men accused of robbing a woman outside her Knoxville residence, ordering her into her home, and confining her inside while they ransacked her property.

In April 2010, Larry Jereller Alston, Kris Theotis Young, and Joshua Edward Webb accosted Carolyn Sue Maples outside her Knoxville residence. The three defendants threatened Ms. Maples at gunpoint, took her purse, then ordered Ms. Maples to enter her home. They followed her inside and pushed her onto the couch, told her not to move, and began ransacking the residence. Police arrived shortly thereafter and apprehended the defendants.

The defendants were charged with aggravated robbery of Ms. Maples’ purse, and with aggravated burglary and especially aggravated kidnapping for the events that followed. They also were charged with firearms offenses. A jury convicted the defendants of all counts. However, in considering the particular circumstances of the case, the trial court later found that the legal principle of due process prohibited convicting the defendants of especially aggravated kidnapping and aggravated burglary in conjunction with aggravated robbery. Consequently, the trial court dismissed the kidnapping, burglary, and firearms offenses. The State appealed.

Meanwhile, the Tennessee Supreme Court issued a decision in a different case, State v. White, which found that when considering kidnapping along with certain other offenses, like robbery, rape, or assault, the jury should be instructed to take into account whether the conduct constituting the kidnapping was incidental to the other offense. Before the decision in White, it was the trial and appellate courts, not the jury, which were responsible for determining whether a kidnapping was incidental to another crime.

After considering the case in light of the White jury instruction requirement, the Court of Criminal Appeals reversed the trial court’s decision and reinstated the defendants’ kidnapping and burglary convictions. The defendants appealed to the Supreme Court, arguing that the conduct constituting the robbery, burglary, and kidnapping convictions was actually part of one ongoing robbery, and had the White jury instruction been given, the jury might have found that the kidnapping was incidental to another offense. The Supreme Court disagreed.

In a unanimous opinion authored by Chief Justice Sharon G. Lee, the Supreme Court affirmed the judgment of the Court of Criminal Appeals, reinstating the defendants’ kidnapping and burglary convictions. First, the Court clarified that a White jury instruction is not required when a defendant is charged with kidnapping accompanied by the offense of aggravated burglary.

Further, the Court found that while the White jury instruction should have been given in the defendants’ trial, which involved charges of especially aggravated kidnapping and aggravated robbery, the instruction would not have changed the outcome. The Court reasoned that the defendants’ aggravated robbery of Ms. Maples’ purse was completed before the especially aggravated kidnapping even began. Thus, it was clear beyond a reasonable doubt that Ms. Maples’ confinement did not occur as a mere incident to the aggravated robbery.

Justice Jeffrey S. Bivins and Justice Holly Kirby joined in a concurring opinion agreeing with the result but urging consideration of a different standard for use in future cases to determine if a defendant can be convicted of both kidnapping and other offenses.  

To read the majority opinion in State v. Larry Jereller Alston, et al., authored by Chief Justice Lee, and the separate opinion of Justice Bivins, visit the opinions sections of TNCourts.gov.

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