State of Tennessee v. Christopher Earl Watts

A Davidson County Criminal Court Jury convicted the appellant, Christopher Earl Watts, of four counts of aggravated child abuse, two counts of aggravated child neglect, and one count of child neglect. After a sentencing hearing, the appellant received an effective sentence of seventy-five years to be served at one hundred percent. On appeal, the appellant contends that (1) the trial court erred by denying his motion to sever the offenses; (2) the trial court erred by instructing the jury that the appellant’s co-defendant was an accomplice; (3) the evidence is insufficient to support the convictions; (4) the trial court erred by failing to merge the appellant’s aggravated child neglect convictions; and (5) his effective sentence is excessive. The State concedes that the trial court erred by failing to merge the appellant’s aggravated child neglect convictions. We conclude that the trial court erred by failing to grant the appellant’s motion to sever but that the error was harmless. We also conclude that the evidence is insufficient to support one of the appellant’s convictions for aggravated child abuse, one of his convictions for aggravated child neglect, and his conviction for child neglect. The appellant’s remaining convictions and effective seventy-five-year sentence are affirmed.