State of Tennessee v. Michael Chad Owens

CourtCourt of Criminal Appeals of Tennessee
DecidedAugust 28, 2025
DocketM2024-01123-CCA-R3-CD
StatusPublished

This text of State of Tennessee v. Michael Chad Owens (State of Tennessee v. Michael Chad Owens) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Tennessee v. Michael Chad Owens, (Tenn. Ct. App. 2025).

Opinion

08/28/2025 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT NASHVILLE June 3, 2025 Session

STATE OF TENNESSEE v. MICHAEL CHAD OWENS

Appeal from the Criminal Court for DeKalb County No. 2020-CR-98 Wesley T. Bray, Judge

No. M2024-01123-CCA-R3-CD

The Defendant, Michael Chad Owens, appeals his DeKalb County convictions for the sale and delivery of heroin and methamphetamine and resulting forty-five-year effective sentence. Specifically, the Defendant challenges that (1) the State failed to sufficiently establish the chain of custody for the narcotics; (2) the evidence was not sufficient to sustain his convictions due to chain of custody issues; (3) his right to confrontation was violated when the confidential informant (“CI”) involved in the controlled buys did not testify at trial; (4) the probative value of the admitted photograph of the CI was substantially outweighed by its danger of unfair prejudice; (5) the Defendant’s alleged impairment at trial prejudiced the jury against him; (6) his sentences are excessive; and (7) the fines imposed by the trial court are excessive. After review, we remand the case to the trial court for a hearing with regard to the fines and for entry of corrected judgment forms reflecting the sentence and fine for each conviction. We affirm the judgments of the trial court in all other respects.

Tenn. R. App. P. 3 Appeal as of Right; Judgments of the Criminal Court Affirmed in Part and Reversed in Part; Case Remanded

KYLE A. HIXSON, J., delivered the opinion of the court, in which JILL BARTEE AYERS and JOHN W. CAMPBELL, SR., JJ., joined.

Mingy K. Ball, Smithville, Tennessee, for the appellant, Michael Chad Owens.

Jonathan Skrmetti, Attorney General and Reporter; Ryan Dugan, Assistant Attorney General; Bryant C. Dunaway, District Attorney General; and Russell C. Tribble and Evan R. Smith, Assistant District Attorneys General, for the appellee, State of Tennessee. OPINION

I. FACTUAL AND PROCEDURAL HISTORY

In June 2019, the Defendant engaged in two transactions, one involving heroin and the other involving methamphetamine, with Jessica Owens, a CI, who was working with the DeKalb County Sheriff’s Office (“DCSO”). From these transactions, a DeKalb County grand jury indicted the Defendant for the sale of heroin (count 1), the delivery of heroin (count 2), the sale of methamphetamine in an amount less than one-half gram (count 3), and the delivery of methamphetamine in an amount less than one-half gram (count 4).1 Tenn. Code Ann. §§ 39-17-417, -434.

Prior to trial, the State moved to admit the audio and video recordings of the controlled buys absent testimony from the CI. The State explained that the CI had passed away and argued that the evidence was still admissible because it could be properly authenticated under Tennessee Rule of Evidence 901(a) by the testimony of law enforcement officers involved in the controlled buys, and the recordings did not violate the Defendant’s right to confrontation because the CI’s statements in the recordings were non-testimonial hearsay.

The Defendant moved to suppress the audio and video recordings of the controlled buys and “any and all reports and testimony regarding the receipt or testing of any drugs” that were turned over to law enforcement by the CI. He argued, in relevant part, that such evidence was inadmissible because it would violate his right to confront the CI and because the CI was the only person able to authenticate the narcotics evidence under Tennessee Rule of Evidence 901. Without this, the State would have no evidence linking the Defendant to the narcotics turned over by the CI. The Defendant additionally objected to “the picture” of the CI being presented at trial because the CI would be unavailable to testify as to the relevance of the photograph or the “true purpose of the alleged meeting.”

A hearing was held on the parties’ motions; however, a transcript of this hearing is not included in the appellate record. In a written order filed on April 6, 2023, the trial court indicated that during this hearing it received evidence regarding the recordings of the controlled buys from the testimony of Detective Steve Barrett with the DCSO. From the evidence presented and the arguments of the parties, the trial court denied the Defendant’s motion to suppress, and pertinent to this appeal, ruled that testimony of law enforcement officers involved in the controlled buys satisfied the requirements of Tennessee Rule of 1 The Defendant was originally indicted in counts 1 and 2 for the sale and delivery of heroin in a drug-free zone. Tenn. Code Ann. §§ 39-17-417, -432. A superseding indictment was returned in April 2023 that removed the drug-free zone component from these counts.

-2- Evidence 901(a) regarding the audio and video recordings of these transactions. Additionally, the trial court ruled that the statements made by the CI in these recordings were not hearsay because these statements were not being offered for the truth of the matter asserted but to provide context for the statements made by the Defendant and to prove there was a conversation regarding the sale of drugs. Therefore, the trial court found that the admission of the recordings did not violate the Defendant’s right to confrontation. The trial court reserved the other evidentiary issues raised for trial.

At trial, Chief Deputy Brian Williams testified that, in 2019, he was a detective with the DCSO. At that time, the CI approached law enforcement about targeting the Defendant for a narcotics investigation. Chief Deputy Williams was familiar with the Defendant and had previously worked with the CI. Two controlled buys were arranged, one for June 21, 2019, with heroin as the targeted substance, and another for June 25, 2019, with methamphetamine as the targeted substance. He stated that the CI had passed away since these transactions occurred. The State showed Chief Deputy Williams two photographs of the CI: a small, black-and-white driver’s license photograph and a color, portrait-style photograph. Chief Deputy Williams responded that he was unable to identify the CI from the driver’s license photograph because he could not tell whether the subject was the CI or the CI’s sister. Chief Deputy Williams was able to identify the subject in the portrait-style photograph as the CI, confirming that the CI looked “about like that around” the time of the controlled buys. The photograph was admitted without a contemporaneous defense objection. During cross-examination, Chief Deputy Williams explained that he was unaware that the photograph was over twenty years old and stated that the CI was in her forties during the controlled buys.

Prior to each controlled buy, the CI met with Chief Deputy Williams and Detective Barrett at a predetermined location. Chief Deputy Williams searched the CI and explained that these searches were to prevent allegations that the CI had narcotics prior to meeting the Defendant. He confirmed that he regularly searched CIs for contraband and was familiar with where contraband was typically concealed.

During Chief Deputy Williams’ testimony, the trial court announced that the parties were going to take up a matter outside the jury’s presence. Once the jury exited the courtroom, the trial court admonished the Defendant for disrupting the trial, stating,

Earlier today[2] under oath you told me that you were not under, look at me, you told me that you were not under the influence of any drug or narcotic. And you keep sitting there and disrupting my courtroom while

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Bluebook (online)
State of Tennessee v. Michael Chad Owens, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-tennessee-v-michael-chad-owens-tenncrimapp-2025.