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Circumstantial Evidence was Sufficient to Prove Child Abuse

In Tennessee, circumstantial evidence alone may be enough to convict someone of a crime, as long as the evidence is convincing beyond a reasonable doubt. In the recent case of State v. Lambright, M2012-02538-CCA-R3-CD (Tenn.Crim.App. 1-7-2014), the Court of Criminal Appeals found the circumstantial evidence sufficient to sustain jury verdicts of guilt of aggravated child abuse.

In the Lambright case, the defendant, who was age seventeen at the time of the offense, had been left to take care of two children in a motel room while the mother was away. The defendant was not related to the children. One child was age two. The other, the victim, was just nine days old. When the victim's mother returned to the room, she found the victim on the floor, covered in blood, with multiple injuries to his face and hands. The injuries appeared to be bite wounds and one finger was bitten almost off. The defendant backed into a corner and repeated that he was "sorry." The two-year old child had dried blood on her chin and chest. When asked if she had bitten the victim, she indicated she had not.

The victim was taken first to Skyline Medical Center and then to Vanderbilt Children's Hospital. At trial, multiple experts who had examined the victim's injuries testified that the injuries could not have been inflicted by the two-year old child.

The defendant's version of events was that he had been sleeping and did not know how the injuries occurred. He claimed he only woke up when he heard the children's mother knocking at the door. Examination of his mobile phone indicated a call had been placed from the phone during the time the defendant claimed to have been asleep.

Though no witness testified to seeing the defendant inflict the injuries, no forensic evidence connected the defendant to the injuries, and the defendant denied he inflicted them, the injuries must have been caused by someone. The evidence was that that there were only three people in the locked motel room when the injuries occurred. The victim could not have inflicted them himself. Experts testified that the two-year old child could not have inflicted them. The only remaining explanation was that the defendant caused the injuries. So the Court concluded the jury verdict finding the defendant guilty was supported by the circumstantial evidence.

For more information on the use of circumstantial evidence in a criminal case, contact Hindman & Associates.

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