TN Court of Criminal Appeals Reverses Evidence Tampering Conviction

• State of Tennessee v. Ashlee N. Appleton

The Tennessee Court of Criminal Appeals decided the case of Ashlee Appleton last week. A jury convicted Appleton of tampering with evidence. The case centers around a murder that occurred on September 8, 2009. There are no accusations that Appleton had any involvement in the murder itself; however, Appleton was charged with tampering with evidence because she admitted to disposing of the gun that was used to commit the murder.

According to Appleton's written confession, given voluntarily after being advised of her Miranda rights, Appleton was at the house with a bunch of her friends. While she was standing in the yard of the house, she heard a pop that sounded like a firework from the other side of the house. She immediately got in her car with some of her friends and drove off. Amidst her journey back to Chattanooga, Jeresse Edwards, the accused shooter, informed Appleton that he had the gun in her car. Wanting to get the gun out of her car, Appelton said she threw the gun off a bridge around the Nickajack Dam.

The State relied on this evidence at trial. Once Appleton was convicted, she appealed to this Court arguing that the State did not satisfy their burden of proving beyond a reasonable doubt that she tampered with the evidence.

The Court of Appeals agreed. The standard used by the Court was "corpus delicti", which means the "body of the crime." In order to obtain a conviction, the State must prove the corpus delicti of tampering with evidence. Two elements are required to prove the corpus delicti: first, that a certain result has been produced, and, second, that the result was created through criminal agency. Because of this standard, the Court reasoned, when a Defendant confesses to a certain crime, some corroborating evidence is required to establish the corpus delicti of the offense charged. The problem with the State's case, the Court held, was that they did not produce enough corroborating evidence to prove that Appleton tampered with the evidence. Specifically, the defendant never admitted to knowing that a gun had been fired, or that anyone had been killed. Further, investigators never found the gun, and the State did not produce any evidence that the Defendant had knowledge that the gun had been used in a crime. Without this corroborating evidence, the Court held, the conviction must be reversed.