State of Tennessee v. Tracy Lorenzo Goodwin, Alias Lawanda Carter

Summary

The Tennessee Supreme Court held that the evidence was insufficient to sustain Tracy Goodwin's two reckless aggravated assault convictions because reckless aggravated assault statutorily requires proof of bodily injury, which was entirely absent from the record, and it remanded for a new trial on simple assault as a lesser-included offense. It affirmed the felony reckless endangerment and criminally negligent homicide convictions, reasoning that abandoning a loaded, cocked shotgun in woods fifty feet from homes created a 'zone of danger' that persisted until the gun was found, and that the children's discovery of the weapon and the ensuing discharge were the natural and probable consequence of the defendant's conduct. The court also held that failure to sever was not error as to the surviving counts because the May 15 altercation evidence would have been admissible contextual background, that the dual convictions for felony reckless endangerment and criminally negligent homicide survive a four-factor double jeopardy analysis, and that the six-year concurrent sentences were not excessive.