Capstone Case Tennessee v. Reeves
On January 5, 1993, Tracie Reeves and Molly Coffman, spoke on the telephone and decided to kill their homeroom teacher, Janice Geiger. Reeves and Coffman were both twelve years old and were students at West Carroll Middle School. They planned that Coffman would bring rat poison to school the following days and it would be put in Geiger's drink. After that, the two would steal Geiger's vehicle and drive to the Smoky Mountains. On January 6, Coffman placed a packet of rat poison in her purse and got on the school bus. Coffman told another student, Christy Hernandez, of the plan. Coffman showed her the poison in her purse. When Hernandez got to school she went and informed her homeroom teacher, Sherry Cockrill. Cockrill then informed the school principal, Claudia Argo. When Geiger entered her classroom that morning, she observed Reeves and Coffman leaning over her deck; and when the girls noticed her, they giggled and ran back to their seats. Geiger saw a purse lying next to her coffee cup on the top of the desk. Shortly after Argo called Coffman to the principal's office, rat poison was found in Coffman's purse. Both Reeves and Coffman gave written statement to the Sheriff investigator concerning their plan to poison Geiger and steal her car.
Reeves and Coffman were found to be delinquent by the Carroll County Juvenile Court, and both appealed from that ruling to the Carroll County Circuit Court. After a jury found that the girls attempted to commit second degree murder in violation of Tenn. Code Ann. Section(s) 19-12-101, the "criminal attempt" statute, the trial court affirmed the juvenile court order and sentenced the girl to the Department of Youth development for an indefinite period. The issue in this case is to determine whether the defendant's action in this case constitute a "substantial step" toward the commission of second degree murder under the new statue. Section 39-12-101 provides, in pertinent part, a person commits criminal attempt that, acting with the kind of culpability otherwise required for the offense:
Intentionally engages in action or causes a result that would constitute an offense if the circumstances surrounding the conduct were as the person believes them to be;
Acts with intent to cause a result that is an element of the offense, and believes the conduct will cause the result without further conduct on the person's part; or
Acts with intent to complete a course of action or cause a result that would constitute the offense, under the circumstances surrounding the conduct as the person believes them to be, and the conduct constitutes a substantial step toward the commission of the offense.
Conduct does not constitute a substantial step under subdivision (a)(3) unless the person's entire course of action is corroborative of the intent to commit the offense.
the Court was faced with the issue of...