Carroll v. State

370 S.W.2d 523 · Tennessee Supreme Court · 1963

Facts

Dolly Carroll, 17, her husband, 18, and their baby lived in apartment 621-D in Memphis, Tennessee. In the early morning of September 8, 1961, the defendant broke into their apartment by cutting a screen and raising a kitchen window. He confronted them with a knife, struck the husband unconscious, and then forced Dolly Carroll to engage in unnatural sexual relations and subsequently raped her. After leaving, the defendant broke into a nearby apartment, 621-F, occupied by Mrs. Edna Sneed, and sexually assaulted her before police arrived and arrested him. The defendant claimed he broke into both apartments by mistake, believing they were his wife's former apartment, to retrieve his clothes, and denied the rape.

Procedural history

The defendant was indicted and charged with rape. A jury found him guilty and fixed his punishment at death by electrocution. The Trial Judge approved the verdict and entered judgment. The defendant appealed this judgment to this Court (the Supreme Court of Tennessee) by an appeal in the nature of a writ of error.

Issue

1. Was the evidence sufficient to sustain the defendant's conviction for rape? 2. Was the testimony of Mrs. Edna Sneed regarding the defendant's subsequent criminal acts in her apartment admissible as evidence?

Holding

Yes, the evidence was sufficient to sustain the conviction for rape. Yes, the testimony of Mrs. Edna Sneed was properly admitted by the trial court. The judgment of the Criminal Court of Shelby County was affirmed.

Rule

In criminal cases, a jury's verdict of guilt, approved by the trial judge, creates a presumption of guilt, and the defendant must show on appeal that the evidence clearly preponderates against the verdict. While corroboration is not legally required for the victim's testimony in rape cases, the charge must be proven beyond a reasonable doubt. Evidence of other crimes is generally inadmissible to prove disposition but is admissible if relevant to a material issue, such as motive, intent, absence of mistake or accident, a common scheme or plan, or identity. Such evidence is also admissible if the crimes are inseparably connected or part of the same transaction.

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