State of Tennessee v. DeWayne Collier aka Patrick Collier

Summary

The Tennessee Supreme Court affirmed DeWayne Collier’s conviction for aggravated statutory rape. The Court held that a victim of statutory rape does not qualify as an accomplice whose testimony requires corroboration, and concluded that the evidence was sufficient to sustain the conviction. The Court also addressed waiver of a challenge to the denial of a motion for judgment of acquittal made at the close of the State’s proof.

Holdings

1. A defendant who presents evidence after the trial court denies a motion for judgment of acquittal made at the close of the State's proof waives any claim of error concerning that motion.
2. A victim of statutory rape is not an accomplice, and the victim's testimony does not require corroboration to support a conviction.
3. The evidence was sufficient to sustain the conviction for aggravated statutory rape.

Questions Presented

1. Whether the defendant waived appellate review of the denial of his motion for judgment of acquittal made at the close of the State's proof by presenting defense evidence after the motion was denied.
2. Whether a minor victim of statutory rape may be treated as an accomplice whose testimony requires corroboration.
3. Whether the evidence was sufficient to sustain the defendant's conviction for aggravated statutory rape.

Disposition

affirmed