State of Tennessee v. Raymond Griffin

The Appellant, Raymond Griffin, was convicted after a trial by jury of twenty-five offenses; two especially aggravated kidnappings, sixteen aggravated robberies, five aggravated burglaries, and two aggravated assaults. Griffin received an effective two-hundred and seventy-year sentence. On appeal, Griffin raises the following issues for our review: (1) whether the trial court erred in admitting his statements into evidence; (2) whether the trial court erred in joining the eight separate criminal episodes for trial; (3) whether the confinement of the victims was essentially incidental to accomplishment of the aggravated robberies and, therefore, sufficient to support separate convictions for especially aggravated kidnapping; (4) whether the evidence was sufficient to support his convictions; and (5) whether the trial court erred in ordering him to serve his sentences consecutively. After review, we find that the trial court erred in joining the eight criminal episodes for trial; however, such error was harmless. We also reverse and dismiss one conviction for especially aggravated kidnapping because the confinement of the victim was essentially incidental to the accomplishment of the aggravated robbery, thereby reducing Griffin’s sentence to an effective two-hundred and forty years. Griffin’s remaining issues are without merit. Accordingly, the judgments of the Shelby County Criminal Court in all other respects are affirmed.