State of Tennessee v. Jesse Wayne Craddock

Summary

The Tennessee Court of Criminal Appeals affirmed Jesse Wayne Craddock’s convictions for felony murder committed in the perpetration of aggravated child neglect and aggravated child neglect, as well as the associated sentences. The court rejected challenges concerning sufficiency of the evidence, vagueness of the aggravated child neglect statute, the denial of a bill of particulars, suppression of evidence seized from Craddock, and the jury instruction on intoxication. The court also rejected the constitutional challenge to the life sentence for felony murder.

Holdings

1. The evidence was sufficient to support the convictions for felony murder and aggravated child neglect. A rational jury could find that Craddock knowingly neglected his infant daughter by consuming alcohol and illicit drugs while solely responsible for her care, that the neglect adversely affected her health and welfare and caused serious bodily injury and death, and that the conduct satisfied the intent requirement for the underlying felony.
2. The State was not required to prove a separate act of neglect to support the aggravated child neglect and felony murder convictions because Craddock was not charged with both aggravated child abuse and aggravated child neglect.
3. The aggravated child neglect statute is not unconstitutionally vague merely because it does not define 'neglect.' The court adopted the reasoning that the ordinary meaning of neglect, together with the statutory elements, gives a person of ordinary intelligence adequate notice of the prohibited conduct.
4. Craddock was not entitled to relief on his challenge to the denial of a bill of particulars because the appellate record did not contain the denial order or hearing transcript, and the available record supported the ruling.
5. Craddock was not entitled to appellate relief on his suppression challenge because the record lacked the suppression ruling and hearing transcript, and the issue was additionally waived by the absence of a plain-error request, reply to the waiver argument, and adequate record citations.
6. The trial court properly refused to instruct the jury on involuntary intoxication because no evidence showed that Craddock's intoxication was involuntary. The court also properly declined to give a voluntary-intoxication instruction because Craddock abandoned that request and voluntary intoxication did not negate the nature-of-conduct mens rea for aggravated child neglect under the evidence presented.
7. The court declined to consider Craddock's Eighth Amendment challenge because he failed to raise it in the trial court, did not request plain-error review, and sought to present an issue of first impression through plain error.

Questions Presented

1. Whether the evidence was sufficient to support convictions for felony murder in the perpetration of aggravated child neglect and aggravated child neglect.
2. Whether Tennessee's aggravated child neglect statute is unconstitutionally vague because it does not define the term 'neglect.'
3. Whether the trial court erred by denying Craddock's motion for a bill of particulars.
4. Whether the trial court erred by denying Craddock's motion to suppress the fentanyl bindle seized from his sock and related body-camera footage.
5. Whether the trial court erred by refusing to instruct the jury on voluntary or involuntary intoxication.
6. Whether Craddock's Eighth Amendment challenge to the mandatory life sentence was preserved or warranted relief.

Disposition

affirmed