Corinio Pruitt was sentenced to death by the State of Tennessee for a carjacking that ended in a murder. According to court documents Corinio Pruitt would pull the elderly victim from his car and proceeded to beat the man to death before stealing his vehicle. Corinio Pruitt would be arrested, convicted and sentenced to death.
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On the morning of August 2, 2005, Courtney Johnson encountered Mr. Pruitt by chance as he walked to the Apple Market on Winchester Road in Memphis, Tennessee. Mr. Pruitt talked about stealing a car and asked Mr. Johnson if he would get in the car with him if Mr. Pruitt took one. Although Mr. Johnson told Mr. Pruitt “no,” he remained with Mr. Pruitt outside the market and spoke to people who came to the market, including Mr. Pruitt’s cousin, Michael Rockett. Later, Mr. Johnson’s friend, “Sed,” came to the market. Mr. Pruitt remained outside the market as Mr. Johnson and Sed walked to the Family Dollar store at the other end of the shopping center. Mr. Johnson testified that he went with Sed to the Family Dollar store because he did not want to be involved in whatever Mr. Pruitt was going to do.
Taka Pruitt2 arrived at the Apple Market with her neighbor. They parked directly outside the front door of the market. Ms. Pruitt stayed in the car while her neighbor went inside. As she waited in the car, she observed a “younger gentleman,” later identified as Mr. Pruitt, standing to the left of the door. Ms. Pruitt recognized him as someone who lived in her apartment complex. After five or six minutes, Ms. Pruitt saw an older man walk out of the market with groceries in his arms and walk to his car. As he reached the driver’s side door, Mr. Pruitt ran up behind the older man and pushed him into the car. Although she could not see clearly into the car, it appeared to Ms. Pruitt that the two men were “tussling.” She saw Mr. Pruitt on top of the older man, and she could see the older man’s feet dangling out of the car. After about fifteen seconds, she saw Mr. Pruitt throw the older man to the ground, slam the car door, and drive away. When Ms. Pruitt checked on the victim, he was shaking and having trouble breathing and he was bleeding from his nose and both ears.
Ms. Pruitt ran inside the market, told employees that someone had just been carjacked,3 and asked them to call 911. She then ran back to the victim and called 911 on her cell phone. Ms. Pruitt went to the police station after the carjacking. She identified Mr. Pruitt from a photo lineup as the person who beat the victim and took the victim’s car. At trial, Ms. Pruitt was shown a still photo created from the market’s security camera video. She circled an image of Mr. Pruitt, identifying him as the younger man she saw push the victim into his car. Ms. Pruitt also confirmed that Mr. Pruitt was alone when he attacked the victim.
Courtney Johnson testified that he saw the victim arrive at the Apple Market in a brown Chevrolet and walk into the market just before he and Sed went to the Family Dollar store. Mr. Johnson said that the victim appeared to be fine when he went into the Apple Market. Mr. Johnson and Sed were in the Family Dollar store for “three to four minutes.” When they walked back in the direction of the Apple Market, Mr. Johnson saw “an old man laying down with blood coming out of his head, and his car was gone.” Mr. Pruitt was also gone. Mr. Johnson said he ran inside the market and asked someone to call 911. He left the scene before the police arrived because he did not want to be involved and did not want to “snitch” on Mr. Pruitt.
Memphis Police Officer Charmell Smith was the first officer on the scene and arrived before emergency medical personnel. She found the victim lying on his back on the ground and bleeding from his ears and mouth. She testified that the victim was “semi-conscious” and that she helped load the victim into an ambulance when it arrived. Based on her prior medical training as a certified nursing assistant, she opined that the bleeding from the ears indicated some kind of head trauma.
Thomas J. Leech, III identified the victim, Mr. Lawrence Guidroz, from a still photo created from the Apple Market’s security camera video. Mr. Leech testified that he had known Mr. Guidroz for more than twenty-five years and that he was very close to Mr. Guidroz. Mr. Leech went to the hospital to see Mr. Guidroz when he heard that Mr. Guidroz had been attacked. Mr. Leech remained in Mr. Guidroz’s hospital room throughout the night. At no point was Mr. Guidroz able to communicate with Mr. Leech. Mr. Guidroz died the next day. Mr. Leech testified that Mr. Guidroz was seventy-nine years old at the time of his death. Mr. Guidroz was buried in Louisiana after a service in Memphis. Mr. Leech identified photographs of Mr. Guidroz’s car, bearing the license plate number CUX 845.
Following the carjacking, Memphis Police began looking for the victim’s car. Officer Jonas Holguin found the car parked at the Somerset Apartments near Tullahoma and Winchester and was instructed to watch it from a distance. At trial, Officer Holguin was shown the photograph of Mr. Guidroz’s car, which had been identified by Mr. Leech, and confirmed that the license plate was the same as the car he was instructed to watch. At some point, the car was moved from the apartment complex without the knowledge of the police, and the police began to search the area in an attempt to locate the car. The car was later observed pulling into a residence at 3180 Beauchamp, and a team of police officers converged on that location.
The driver of the car, who was wearing a red shirt, went inside the house. The police made the decision to apprehend the driver. Mr. Johnson came out of the house and the police took him into custody. According to Sergeant Robin Hulley, Mr. Johnson yelled, “the guy you want is in the back yard.” Officers went to the back yard and saw a man wearing a red shirt jump over a fence and run. Although dogs were called in to track the man, police had no success in finding him.
Mr. Johnson testified that after the incident at the Apple Market, he did not see Mr. Pruitt again until three days later, when Mr. Pruitt telephoned and asked to come to Mr. Johnson’s house to take some liquor from Mr. Johnson’s grandmother’s bar. Because he knew Mr. Pruitt had stolen the victim’s car, Mr. Johnson told Mr. Pruitt not to come to his house.
Nevertheless, Mr. Pruitt drove to Mr. Johnson’s house and parked the car in the garage. Shortly thereafter, three to four unmarked police cars arrived on the scene. Mr. Johnson knew that the police were there for Mr. Pruitt. Although Mr. Johnson was not aware that Mr. Guidroz had died, Mr. Pruitt informed Mr. Johnson that he had “body-slammed” the victim before taking his car. At trial, Mr. Johnson identified a photograph of himself with Mr. Pruitt at the Apple Market on the day of the carjacking and identified the victim’s car as the one Mr. Pruitt parked in his garage. Mr. Johnson was never charged in the case.
The car was taken to the crime scene investigation office, where Officer Francis Donald Carpenter processed the car for fingerprints. Officer Carpenter testified that he found several latent prints on the car. Two prints were lifted from the outside windshield on the front passenger side. Officer Nathan Gathright, a latent fingerprint examiner for the Memphis Police Department, testified that these prints belonged to Mbenda McCracken. A print found on the left rear fender outside the car belonged to Kendricks Scott.4 Another print found on the right rear fender above the wheel belonged to Mr. Pruitt.5 Both Mr. McCracken and Mr. Scott testified at trial.
Mr. McCracken identified Mr. Pruitt in the courtroom. In August 2005, Mr. McCracken had known Mr. Pruitt for approximately eight months. Mr. McCracken identified a photo of the victim’s car and stated that he saw Mr. Pruitt driving the car in August 2005. When Mr. McCracken asked Mr. Pruitt where the car came from, Mr. Pruitt told him it was his girlfriend’s car. Mr. McCracken got into the car and went with Mr. Pruitt to buy beer and marijuana. Mr. Pruitt, Mr. McCracken, and a friend named “Fred” drove around in the car for three to four hours and got high. Mr. McCracken later saw on the news that the car Mr. Pruitt was driving had been taken in a carjacking. Mr. McCracken denied any involvement in the carjacking.
Before Mr. McCracken testified, he and Mr. Pruitt were accidentally placed in the same holding cell for about forty-five minutes. Mr. McCracken was in custody on an aggravated burglary charge unrelated to the present case. Mr. McCracken testified that while he and Mr. Pruitt were in the holding cell, Mr. Pruitt told Mr. McCracken that there were two persons involved in the carjacking and that the other person had not been charged. Mr. Pruitt said that he and the other person were trying to get into the victim’s car. When the victim approached the car, they jumped on him. Mr. Pruitt told Mr. McCracken that he grabbed the victim and threw him down. Mr. Pruitt tried to persuade Mr. McCracken to testify that he did not know Mr. Pruitt and that another man came into the neighborhood to attempt to sell Mr. McCracken parts from the car.
Kendricks Scott, whose fingerprints were found on the left rear fender, testified that he saw Mr. Pruitt driving the victim’s car in August 2005. Mr. Pruitt offered Mr. Scott a ride to work and told Mr. Scott that it was “his auntie’s car.” Mr. Scott opened the rear door of the car and briefly sat in the back seat with the door open, but did not ride in the car. Another person, whom Mr. Scott did not know, was in the car at the time. The following day, when the police came looking for Mr. Pruitt at the house next door to Mr. Scott’s residence,6 Mr. Scott learned that the car had been taken in a carjacking. Mr. Scott did not volunteer any information to the police at that time.
Alma Rockett is Mr. Pruitt’s aunt. Mr. Pruitt was living with Ms. Rockett in the Somerset Apartments in August 2005. On August 2, 2005, Ms. Rockett recognized Mr. Pruitt in video footage shown on a television news broadcast. She also recognized another man in the video who previously had been in her home with Mr. Pruitt. At trial, she was shown still photographs from the Apple Market security video. Ms. Rockett identified Mr. Pruitt as the man wearing the dark-colored shirt, a larger man as her son, Michael, and a smaller man as the man who previously came home with Mr. Pruitt. She also identified Michael’s car in the photograph with the three men. After seeing the video footage on the news, Ms. Rockett and her son went downtown “to straighten it out, to let them know that [Michael] was not involved.” After that night, Mr. Pruitt never came back to her house. When Mr. Pruitt later called Ms. Rockett, she told him to turn himself in to police.
Mr. Pruitt testified in his own defense. He acknowledged his prior convictions for aggravated burglary, robbery, criminal attempt to commit robbery, and theft over $500. He stated that on the morning of August 2, 2005, he left for work around 6:00 a.m. When he arrived at work, however, he discovered he had left his identification badge at home. Although he called his aunt to confirm the badge was there, he never went home to get it. Instead, Mr. Pruitt went to Courtney Johnson’s house and arrived between 8:00 and 8:30 a.m.
Mr. Pruitt stated that he and Mr. Johnson talked for awhile and went to the Apple Market for the express purpose of stealing a car. While they were standing by the drink machine attempting to decide which car to steal, Mr. Pruitt’s cousin, Michael, arrived and went into the market. When Michael came out of the market, Michael, Mr. Johnson, and Mr. Pruitt walked to the Family Dollar store. Mr. Pruitt stated that Michael bought something, and the three of them returned to the front of the Apple Market by the drink machine until Michael left. Mr. Pruitt acknowledged seeing Taka Pruitt arrive at the market. He claimed that he and Mr. Johnson knew her because “[they] smoke[d] weed with her.”
Mr. Johnson spoke to Mr. Guidroz when he arrived at the market. After Mr. Guidroz went inside, Mr. Johnson walked toward the Family Dollar store because he did not want to be seen on the surveillance camera. According to Mr. Pruitt, Mr. Johnson “popped up on the other side” from where Mr. Pruitt was and “scoped out” Mr. Guidroz’s car. Mr. Pruitt testified that he was the lookout while Mr. Johnson got inside the car.
According to Mr. Pruitt, when Mr. Guidroz came out of the store, he saw Mr. Johnson in Mr. Guidroz’s car. Mr. Guidroz began struggling with Mr. Johnson. Mr. Pruitt ran up to Mr. Guidroz, grabbed him, and “slung him” into the car. He believed that Mr. Guidroz fell to the ground after he hit the car. Mr. Pruitt admitted pushing Mr. Guidroz hard. Mr. Pruitt testified that he was scared and that he got into the car and drove it to Mr. Johnson’s house on Beauchamp. Mr. Johnson did not get into the car with him. When Mr. Johnson came home, Mr. Pruitt left. Mr. Pruitt testified that he did not have a gun at the time he took the victim’s car and that his intent was to steal the car and sell its parts.
The next day, Mr. Johnson called Mr. Pruitt and met him at the Somerset Apartments, where Mr. Pruitt was staying. The car was parked at an apartment complex across the street from the Somerset Apartments. Mr. Pruitt believed that Mr. Johnson was the person who moved the car to that location. Mr. Pruitt stated that on August 3, 2005, he and Mr. Johnson went back to Mr. Johnson’s house in the victim’s car and drove it into the garage. When the police arrived, Mr. Pruitt ran because he was scared. He claimed he did not know at the time that the victim had died. The following day, Mr. Pruitt turned himself in and gave a statement to the police.
When cross-examined about his statement to the police, Mr. Pruitt admitted that he told police he left Mr. Johnson standing outside the Family Dollar store when he took the victim’s car. He admitted telling police that he did not leave the victim’s car at Mr. Johnson’s house. He also admitted telling police that he drove a number of friends around and that he let his friend, Reggie, use the car. Mr. Pruitt stated that he initially lied about Mr. Johnson’s involvement because he did not want to “snitch” on him. Mr. Pruitt admitted that his version of the events did not match the security video, which shows Mr. Johnson walking to the Family Dollar store before the carjacking and walking back after the carjacking. He said that most of his statement to police was true. As to any inconsistencies between his version of events and the testimony from Taka Pruitt and Mr. McCracken, he claimed both were lying. He maintained that he did not intend to hurt the victim.
The State presented medical evidence regarding Mr. Guidroz’s injuries. Dr. Karen Chancellor, the Chief Medical Examiner in 2005 for Memphis and Shelby County, Tennessee, performed Mr. Guidroz’s autopsy. As a result of her internal and external examinations of Mr. Guidroz, Dr. Chancellor concluded that the cause of Mr. Guidroz’s death was multiple blunt force injuries sustained to the head and chest and that the manner of Mr. Guidroz’s death was homicide.
Dr. Chancellor found an abrasion on the front of Mr. Guidroz’s face and a laceration on the left side of his forehead. She also noted that “there [was] ecchymosis or hemorrhag[ing] around both eyes, and that was caused by skull fractures ․ found inside the body.” The injuries to Mr. Guidroz’s body included bruising on the ear, the right and left side of the chest, the upper left arm, the neck and shoulder, the right ankle, the backs of both hands, both forearms, and the lips. Dr. Chancellor opined that all the victim’s bruises were caused at the same time and at the time of the incident at the Apple Market.
As to her internal examination of Mr. Guidroz, Dr. Chancellor noted that “there was quite a bit of hemorrhage overlying the ribs on the left side” and a complete fracture of the clavicle. Eleven ribs on Mr. Guidroz’s left side were fractured, with resulting bruises on the surrounding lung tissue. Dr. Chancellor remarked that Mr. Guidroz had extensive blunt force injuries to his head, which included skull fractures, bruises to brain tissue, and hemorrhaging around the brain. In addition, Mr. Guidroz suffered a subdural hematoma, which required surgery to avoid severe brain injury. She opined that the skull fractures were caused by at least three separate blows or impacts to the left side of the head. Mr. Guidroz also suffered fractures to the orbital plates directly above the eyes, which resulted in blood collecting around his eyes.
Dr. Chancellor was unaware that Mr. Guidroz had coagulopathy, a condition making him prone to bleed, but she was aware that Mr. Guidroz had severe coronary atherosclerosis, a blockage of the blood vessels of the heart. No evidence of surgical intervention for these blockages was present. Dr. Chancellor did not collect any of Mr. Guidroz’s fractured bones during the autopsy. Dr. Chancellor stated that, although the practice of removing bones during autopsy was once “in vogue,” the practice is no longer common. She also did not conduct a bone density test on Mr. Guidroz because a bone density test is not a routine part of an autopsy. Although she opined that Mr. Guidroz’s injuries were consistent with being beaten, she was not able to determine the order of his injuries or whether his injuries resulted from being struck by a hard object, being forcibly thrust against a hard object, or a combination of these two actions. She did not believe, however, that a fall alone would have caused all of his injuries.
The defense introduced testimony from Dr. O.C. Smith, former Chief Medical Examiner for Shelby County, Tennessee. Dr. Smith reviewed the medical examiner’s files and Mr. Guidroz’s medical records in July 2007. Dr. Smith noted several deficiencies in the autopsy record. He commented on the absence of X-rays taken as part of the autopsy procedure and the absence of bones for review. Dr. Smith testified that bones can be excised, cleaned, and retained in inventory, or can be preserved with photographs or X-rays. Dr. Smith testified that when he was the medical examiner, the lab was able to test for bone density either by X-ray or by excising the bone and examining it. He opined that loss of bone density due to age or osteoporosis could have made Mr. Guidroz’s bones more vulnerable to trauma. Dr. Smith’s routine practice when he was medical examiner was to excise every fractured bone in a homicide or suspected homicide. He also commented that he was unable to examine Mr. Guidroz’s brain specimen because the preserving fluid had been allowed to dry out.
Dr. Smith testified that Mr. Guidroz’s medical records indicated he suffered from coagulopathy, which made him prone to bleed. Mr. Guidroz lost 1.5 liters of blood during his brain surgery, which required a transfusion of blood, fresh frozen plasma, and platelets. Dr. Smith opined that the coagulopathy, together with the blockages in Mr. Guidroz’s heart, made him particularly vulnerable to injury. The coagulopathy also would have caused “seepage” of blood during surgical procedures, which would have made Mr. Guidroz’s injuries look worse than they actually were. The ecchymosis, or hemorrhaging or bleeding under the skin, on various parts of Mr. Guidroz’s body also could have been exacerbated by the coagulopathy. Dr. Smith discussed a condition known as “senile ecchymosis” that occurs as part of the aging process and opined that some of Mr. Guidroz’s ecchymosis might be attributable to his age. He explained that with such a condition, even minor trauma can cause bruising with superficial bleeding on the skin’s surface. He conceded that the ecchymosis could be from the original injuries but thought that it was probably a combination of surgery and original injury. Dr. Smith agreed that blood beneath the skin on the left side of Mr. Guidroz’s neck likely resulted from the fracture and dislocation of the clavicle and fractures of the adjacent ribs, not from surgery.
Dr. Smith found evidence of a “contre-coup” or “decelerating” brain injury and distinguished between accelerative trauma and contre-coup trauma. Accelerative trauma occurs when a moving object strikes a fixed head and leaves a bruise on the skin and causes damage in the area of the brain immediately beneath the blow. A contre-coup injury, however, is decelerative trauma caused when a moving head hits a fixed object. Injury to the skin occurs at the point of impact, but the injury to the brain occurs on the opposite side of the head. Dr. Smith testified that, although the fractures of Mr. Guidroz’s skull were on the left side of his head, he suffered a contre-coup injury to the right side of his brain, indicating that his injuries occurred in a fall.
Dr. Smith noted that the fractures to the clavicle, ribs, and head were all on Mr. Guidroz’s left side and opined that the cause of death was “a fall to a flat surface or some contact where the body is in motion, and then it’s been arrested by a hard, unyielding surface.” Dr. Smith opined that the fall could have been from a standing height, from running and falling, from falling from a height, or from being propelled, depending on the strength of Mr. Guidroz’s bones and the force that caused the fall. He ruled out the possibility that blows or strikes to Mr. Guidroz’s body were the sole cause of his injuries.
Dr. Smith agreed with Dr. Chancellor that the manner of Mr. Guidroz’s death was homicide and the cause of Mr. Guidroz’s death was blunt force injury to his head and chest. He also agreed that Mr. Guidroz’s injuries were consistent with a scenario of
being pushed in on the left-hand side of his car—something was going [on] in that front seat of the car to the point that an eye witness saw Mr. Guidroz’s feet dangling ․ out of the driver’s side door with the [d]efendant on top of him, and then the next thing that an eye witness sees is this [d]efendant pick up the body of Mr. Guidroz and sling him out of [the] car onto the concrete.
Dr. Bruce Levy, then Chief Medical Examiner for the State of Tennessee and the Medical Examiner for Davidson County, testified for the State in rebuttal. Although Dr. Smith’s routine practice during his tenure was to remove bones from the body and store them, Dr. Levy testified that this practice was unique to Memphis and uncommon. In Dr. Levy’s opinion, Dr. Chancellor, who actually performed the autopsy, was in the best position to render opinions as to what she saw and to interpret her observations. In his view, she followed the standard practice of documenting the autopsy by photographs, diagrams, and narratives describing what she saw.
Dr. Levy stated that Mr. Guidroz suffered blunt force trauma injuries. He opined that the victim’s skull fractures, which were indicative of at least two separate blows, combined with the fractures to the ribs and clavicle, led to a “differential diagnosis.” In other words, there could be different causes for the injuries: either a fall from some height, a car collision, or an accelerated fall in which the victim was thrown to the ground with some force. Dr. Levy opined that breaking eight or nine ribs was not consistent with a simple fall to the ground, but might be consistent with an accelerated fall. Likewise, the multiple injuries to the chest, arms, face, and head were inconsistent with a simple fall.
He testified that when faced with a differential diagnosis, a medical examiner will rely on the history of the case. In this case, the anecdotal reports that Mr. Guidroz was assaulted in a carjacking and thrown to the ground were factors in determining the cause of his injuries. Dr. Levy testified that “body-slamming” can cause multiple fractures like the ones observed in Mr. Guidroz. The presence of complex skull fractures was indicative of a significant amount of force, “much greater than you could possibly get from simply falling to the ground and striking your head on a flat surface.”
Based on the evidence, the jury convicted Mr. Pruitt of first degree felony murder in the perpetration of a robbery. The jury also convicted Mr. Pruitt of second degree murder as a lesser-included offense of the charged first degree premeditated murder. The trial court merged the two convictions and proceeded to the penalty phase.