Background
Louis L. Steele, an inmate at Whiteville Correctional Facility in Hardeman County, Tennessee, was indicted for indecent exposure in a penal institution. The charge arose from two incidents on July 7, 2024, during which Correctional Officer Anne Rourke observed Steele masturbating at his cell door while she conducted routine hourly checks. During her first pass, she warned Steele to stop; he laughed in her face and did not comply. On her second hourly check, after announcing her presence as was her custom when a female officer entered the unit, Steele repeated the behavior and again laughed when she told him to stop. She then issued a formal written report.
C.O. Rourke testified that the incidents left her feeling embarrassed, disgusted, and targeted, and that she believed Steele acted deliberately to harass her in retaliation for her prior warning. Steele did not testify and presented no evidence at trial. A Hardeman County jury convicted him of one count of indecent exposure in a penal institution under T.C.A. § 39-13-511(c)(1)(A), and the trial court imposed a Range II, three-year sentence in the Department of Correction, to run consecutively to a separate Davidson County sentence.
Steele filed a motion for new trial, which the trial court denied. He then appealed to the Court of Criminal Appeals, arguing solely that the evidence was insufficient to support the conviction.
The Court’s Holding
The Court of Criminal Appeals affirmed the conviction in a unanimous opinion authored by Judge Jill Bartee Ayers, joined by Judges McMullen and Campbell. Applying the standard that a conviction must stand if any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt, the court held that the evidence was sufficient. The court found that C.O. Rourke’s testimony — that Steele exposed himself by masturbating at his cell door, laughed when ordered to stop, and repeated the conduct on her very next round — was adequate for a rational jury to conclude he acted with the requisite intent to harass or embarrass a guard.
The court rejected Steele’s argument that C.O. Rourke’s testimony was contradictory and that her failure to write him up after the first incident undermined any inference of harassment. Under settled Tennessee law, credibility determinations and resolution of evidentiary conflicts belong exclusively to the jury, and the jury’s guilty verdict — approved by the trial court — resolved those conflicts in the State’s favor. The court likewise dismissed Steele’s claim that C.O. Rourke’s assessment of his intent was mere speculation, finding her observations of his conduct and her own stated emotional reaction provided a sufficient evidentiary basis for the jury’s finding.
Key Takeaways
- Tennessee’s indecent exposure statute, T.C.A. § 39-13-511(c)(1)(A), is satisfied when an inmate intentionally exposes genitals to a correctional officer with intent to abuse, torment, harass, or embarrass; a verbal statement of intent is not required — the jury may infer intent from conduct and circumstances.
- A correctional officer’s testimony about her own emotional response (embarrassment, disgust, feeling targeted) is competent, non-speculative evidence from which a jury may infer the defendant’s intent to harass or embarrass.
- On sufficiency review in Tennessee, appellate courts view evidence in the light most favorable to the State and will not disturb a jury’s credibility determinations or resolution of testimonial conflicts, even where the officer’s response to the first incident differed from her response to the second.
Why It Matters
This decision reinforces that Tennessee courts will uphold indecent exposure convictions in correctional settings based on circumstantial evidence of intent derived from an inmate’s conduct and a victim officer’s firsthand account — without requiring corroborating witnesses, physical evidence, or an explicit statement of purpose by the defendant. Defense challenges premised on minor inconsistencies in an officer’s testimony or on the argument that her reaction was not sufficiently immediate face a high bar on appeal.
For correctional facilities and prosecutors, the case illustrates that documenting an officer’s contemporaneous emotional reaction and the sequence of events — particularly where an inmate repeats the behavior after a warning — is sufficient to establish the harassment element and withstand appellate scrutiny.