State of Tennessee v. Jeffery Ray Watts

10/29/2026 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT NASHVILLE Assigned on Briefs August 11, 2026 STATE OF TENNESSEE v. JEFFERY RAY WATTS Appeal from the Circuit Court for Hickman County No. 24-5026CR Michael E. Spitzer, Judge No. M2025-00728-CCA-R3-CD The Defendant, Jeffery Ray Watts, was convicted by a Hickman County Circuit Court jury of evading arrest with a motor vehicle creating a risk of death or injury, a Class D felony; reckless endangerment with a deadly weapon, a Class E felony; and leaving the scene of an accident, a Class B misdemeanor. See T.C.A. §§ 39-16-603 (2025) (evading arrest), 39- 13-103 (2025) (reckless endangerment), 55-10-102 (2024) (leaving the scene of an accident). The trial court imposed an effective two-year sentence in confinement. On appeal, the Defendant contends that his initial traffic stop, detention, and subsequent arrest were unconstitutional, that the evidence is insufficient to support his convictions, and that he is entitled to relief due to the cumulative effect of errors in the trial court proceedings. We affirm the judgments of the trial court. Tenn. R. App. P. 3 Appeal as of Right; Judgments of the Circuit Court Affirmed ROBERT H. MONTGOMERY, JR., J., delivered the opinion of the court, in which ROBERT W. WEDEMEYER, P.J., and J. ROSS DYER, J., joined. Melanie T. Cagle, District Public Defender; John Schweri (on appeal and at trial) and Michael Auffinger (at trial), Assistant District Public Defenders, for the appellant, Jeffery Ray Watts. Jonathan Skrmetti, Attorney General and Reporter; Caroline W. Weldon, Senior Assistant Attorney General; Hans L. Schwendimann, District Attorney General; and Beverly J. White and Jacob R. McElyea, Assistant District Attorneys General, for the appellee, State of Tennessee.  OPINION The Defendant’s convictions relate to a November 30, 2023 traffic stop and subsequent car and foot chase. On February 7, 2024, the Hickman County Grand Jury indicted the Defendant for the following: evading arrest with a motor vehicle creating a risk of death or injury (Count 1); aggravated assault (Count 2); reckless endangerment with a deadly weapon (Count 3); assault on a first responder (Count 4); evading arrest (Count 5); resisting arrest (Count 6); leaving the scene of an accident (Count 7); violation of the financial responsibility law (Count 8); and failure to provide immediate notice of an accident (Count 9). Count 9 was dismissed before the trial. The Defendant was found guilty of Counts 1, 3, and 7. The jury found the Defendant not guilty of the remaining counts. I Trial Hickman County Sheriff’s Department (HCSD) Deputy David Martinez testified that, while in “a high traffic area for crime,” he followed the Defendant’s car and stopped it because it crossed the double yellow line “numerous” times and because the Defendant failed to dim his car’s headlights for oncoming traffic. Deputy Martinez recalled that HCSD Lieutenant David Nordan parked his patrol car behind Deputy Martinez’s car. Lieutenant Nordan walked toward the driver’s window. Deputy Martinez said that he approached the passenger-side window, told the Defendant that he had failed to dim the car’s headlights, and asked him for his driver’s license, car registration, and proof of insurance. The Defendant provided Deputy Martinez with his driver’s license and car registration. Deputy Martinez described the Defendant as “nervous, unsteady, shaking, [and] continually looking around” and said that he believed the Defendant was not being truthful. Deputy Martinez said that he asked the Defendant to step out of the car because of his safety concerns and because he suspected that the Defendant might be impaired. Deputy Martinez said that the front seat passenger identified himself as Donald Watts and the back seat passenger as Adam Watts. Deputy Martinez testified that during the stop the Defendant became “more erratic with looking around” and “verbally noncompliant.” Deputy Martinez said he asked the Defendant to step out of the car, but the Defendant questioned whether Deputy Martinez had probable cause to do so. Deputy Martinez stated that the Defendant did not comply with his request and that the Defendant “rapidly slammed his car into gear” and drove off at a high rate of speed, leaving Deputy Martinez standing beside the road and holding the Defendant’s driver’s license. -2-  Deputy Martinez testified that he returned to his patrol car and that he and Lieutenant Nordan separately pursued the Defendant’s car. Deputy Martinez said that Lieutenant Nordan tried to maneuver his car in front of the Defendant and that “[a]t that time, . . . [the Defendant] started to slow his vehicle. The front seat passenger jumped out. The back seat passenger attempted to jump out.” Deputy Martinez recalled that he chased the Defendant’s car down the two-lane road for approximately one-quarter mile before the Defendant’s car flipped. Deputy Martinez stopped and requested an ambulance. Deputy Martinez testified that as he approached the Defendant’s car, the Defendant climbed out of the front passenger window and ran across a field. Deputy Martinez said that he ran after the Defendant and, when he was within range, twice fired his Taser. Deputy Martinez thought the Taser’s probes hit the Defendant’s leather jacket both times. The Defendant jumped over a fence. Deputy Martinez recalled that after he climbed over the fence, the Defendant engaged him in a fist fight. Deputy Martinez said that Lieutenant Nordan fired his Taser once and then “drive-stunned” the Defendant by applying the Taser directly to the Defendant’s skin. Deputy Martinez said that he handcuffed the Defendant and placed him in a seated position when he complained that he could not breathe. Deputy Martinez recalled that the Defendant collapsed to the ground complaining of chest pain when officers attempted to place him in a patrol car. Deputy Martinez testified that he rendered emergency medical aid and believed the Defendant was getting oxygen because the Defendant was talking. Deputy Martinez said that he saw the Defendant’s face and lips turn blue and his eyes roll back. He said the Defendant’s speech was slurred. Deputy Martinez said that he administered Narcan in the event the Defendant was suffering from a drug overdose. Deputy Martinez related that, after administering Narcan, the Defendant said he did not use drugs. Deputy Martinez related that while waiting to transfer the Defendant to an ambulance, the Defendant stated that he was a “wanted felon.” Deputy Martinez said that the Defendant was taken by ambulance to the Natchez Trace Emergency Room. Deputy Martinez’s body camera video recording of the traffic stop and arrest was received as an exhibit and played for the jury. The recording reflected that Deputy Martinez stopped the Defendant’s car and approached the front passenger-side window. He informed the Defendant that the Defendant had failed to dim his headlights for oncoming traffic and asked the Defendant and passengers for identification. Deputy Martinez also asked the Defendant to step out and speak with him. The Defendant asked, “[F]or what reason?” Deputy Martinez replied, “I need to run your licenses and do my checks.” The Defendant then sped off in his car, leaving Deputy Martinez standing beside where the car had been parked. Deputy Martinez ran to his patrol car and pursued the Defendant. During the car chase, the recording did not show the road, but Deputy Martinez could be heard telling dispatch that the Defendant was “running,” that the Defendant’s car had flipped, and that emergency medical services were needed. The recording showed the -3- Defendant’s car, which was upside down, and the Defendant climbing out of the passenger window and running into the darkness. Deputy Martinez chased the Defendant. Deputy Martinez’s flashlight illuminated only a few feet in front of him as he chased the Defendant. The Defendant suddenly appeared in the recording and lunged toward Deputy Martinez. A fight ensued. The sound of a Taser could be heard. Deputy Martinez told the Defendant “to quit” and to put his “hands behind your back.” The Defendant responded “f--- you.” Deputy Martinez told the Defendant to “quit trying to bite me” and the sound of the Taser could be heard again. After the Defendant was subdued, Deputy Martinez alerted the EMS technicians that there had been “multiple Taser deployments.” The Defendant complained that he could not breathe and officers were unable to help the Defendant walk to the patrol car. Deputy Martinez performed a brief medical check of the Defendant, administered Narcan, applied a cervical collar, and checked the Defendant’s breathing, blood pressure, and pulse. The Defendant denied using any illegal drugs. One of the officers at the scene stated that passengers in the Defendant’s car had jumped out of the car and that one passenger almost got hit by another car. EMS technicians arrived, the Defendant was given additional Narcan, and the Defendant was taken away by ambulance. Deputy Martinez testified that he sustained a broken nose, a severely sprained knee, and double vision because of the fight. Deputy Martinez’s medical records and a photograph of his broken nose were received as exhibits. Lieutenant Nordan’s body camera video recording of the traffic stop and the Defendant’s arrest was received as an exhibit and played for the jury. It was consistent with Deputy Martinez’s body camera recording. Deputy Martinez testified that each Taser could fire only two shots and that, after both shots had been fired, a Taser could still be used to drive-stun. Deputy Martinez explained that the Taser makes a louder noise when it connected to a suspect’s clothing and not the suspect’s skin. On cross-examination, Deputy Martinez testified that he was assigned to the narcotics division but also enforced traffic violations. Deputy Martinez agreed that he frequently parked at the subdivision where he first saw the Defendant and that, during his career, he had arrested as many as thirty people leaving that subdivision. Deputy Martinez said that he followed the Defendant for a few miles and that the Defendant failed two or three times to dim his headlights for approaching cars. Deputy Martinez described the road as curvy and recalled that the Defendant crossed both the double yellow line and the white fog line. Deputy Martinez agreed that he did not tell the Defendant that he was being stopped because he failed to maintain his lane. Deputy Martinez said that he did not search the Defendant’s car and that he did not believe the Defendant had any weapons. Deputy Martinez acknowledged that he never told the Defendant that he was not free to leave nor did he tell the Defendant that he was under arrest. Deputy Martinez said that he did not -4- advise the Defendant of his Miranda rights. Deputy Martinez denied using excessive force against the Defendant and agreed that he did not charge the Defendant with a traffic violation. Deputy Martinez acknowledged that he had been investigated in the past for the use of force. Deputy Martinez agreed that he filled out a force report regarding this incident stating that his Taser was not effective. Deputy Martinez testified that the typical resolution of a traffic stop for failing to dim headlights would be a verbal warning, a written warning, or a citation. Deputy Martinez stated that he asked the Defendant to step out of the car to observe his behavior, despite the fact that the Defendant did not appear intoxicated. Deputy Martinez acknowledged that he believed there was an “impending sense of danger” that led him to chase the Defendant. Deputy Martinez denied hitting the Defendant’s face. Deputy Martinez stated that he did not have probable cause to ask the Defendant to step out of the car. Five additional use-of-force reports regarding Deputy Martinez’s use of a Taser in other incidents were received as a collective exhibit. On redirect examination, Deputy Martinez testified that he was patrolling the area near the subdivision because it was a heavy traffic area and because HCSD had received numerous complaints of speeding and other traffic infractions in that area. Deputy Martinez said that he chased the Defendant because, after the Defendant drove away at a high rate of speed, the Defendant became a danger to the public. Deputy Martinez agreed that a use-of-force report was generated whenever a Taser was used and did not denote that the use of force was inappropriate. Deputy Martinez stated that he had probable cause for the traffic stop. Lieutenant Nordan testified that he assisted Deputy Martinez during the traffic stop. Lieutenant Nordan said that he stood on the opposite side of the car from Deputy Martinez until the car fled. Lieutenant Nordan recalled that he pursued the Defendant’s car, and while doing so, saw the car’s two occupants get out of the car. Lieutenant Nordan said he continued down the road until he found the Defendant’s car partially on the road and upside down. Lieutenant Nordan stated that he followed Deputy Martinez and saw Deputy Martinez and the Defendant “grappling each other” in a struggle. Lieutenant Nordan told Deputy Martinez to move and then fired his Taser into the Defendant’s back to “stop his resistance.” Lieutenant Nordan explained that Deputy Martinez struggled while trying to handcuff the Defendant. Lieutenant Nordan noted that the Defendant continued to resist and, as a result, Lieutenant Nordan used the Taser to drive-stun the Defendant. Lieutenant Nordan recalled that the Defendant was told the Taser would not be used if he stopped resisting. Lieutenant Nordan stated that no one punched the Defendant’s face. Lieutenant Nordan said that the Defendant received medical care after being handcuffed because the Defendant appeared to be under the influence of something, was losing consciousness, and his face turned purple. Lieutenant Nordan recalled that, after receiving Narcan, the Defendant was more alert and able to speak. Lieutenant Nordan’s body camera recording -5- of the Defendant receiving medical care at an emergency room was received as an exhibit and played for the jury. On cross-examination, Lieutenant Nordan testified that he did not tell the Defendant that the Defendant was not free to leave nor that he was under arrest. Lieutenant Nordan acknowledged that a Taser was used on the Defendant when one of the Defendant’s hands was secured in a handcuff. Lieutenant Nordan said that excessive force was not used during the Defendant’s arrest. Lieutenant Nordan recalled that he only fired his Taser once and did not know how many times a Taser was used to subdue the Defendant. Hickman County Jail nurse Kelly Hill testified that the Defendant arrived at the jail with a facial bruise and a neck sprain or strain and that she did not observe any additional injuries, although she noted that the Defendant’s teeth showed signs of decay. Ms. Hill said that, after approximately one week’s confinement, the Defendant complained of dental and left wrist pain, that X-ray images confirmed a broken bone in his wrist, and that the Defendant had surgery to repair the break. The Defendant’s medical records were received as an exhibit. Adam Watts, the Defendant’s brother, testified that he was seated in the backseat on the passenger side of the car at the time of the traffic stop, that he provided his name to Deputy Martinez, and that Deputy Martinez called his brother “Jeremy” instead of “Jeffery.” Adam Watts said that the Defendant refused to step out of the car when asked to do so and, instead, “took off.” Adam Watts stated that the other passenger in the car was Donald Watts, who was his and the Defendant’s uncle. Adam Watts explained that after Donald Watts jumped out of the car, he jumped out of the car and rolled and that a patrol car swerved to avoid hitting him. Adam Watts recalled that before being stopped by Deputy Martinez, he, the Defendant, and their uncle had worked at the uncle’s house. Adam Watts stated that the Defendant did not fail to dim his headlights or fail to maintain his lane before being stopped. Donald Watts testified that he was seated in the front passenger seat of the Defendant’s car at the time of the traffic stop. Donald Watts said that he and the Defendant provided identification to Deputy Martinez, that Deputy Martinez asked the Defendant to step out of the car, and that Deputy Martinez gave no reason why he wanted the Defendant to step out of the car. Donald Watts said that the Defendant drove off, that he asked the Defendant to let him out of the car, and that the Defendant stopped the car to let him out. The Defendant testified that he dimmed his headlights when passing cars on the road and that he stayed in his lane. The Defendant stated that he stopped his car when signaled and that Deputy Martinez approached the passenger side of the car, called him “Jeremy,” and asked for his identification. The Defendant said that he gave his driver’s license to Deputy Martinez. The Defendant said that he was nervous because he was on -6- federal pretrial release, that he was in the middle district of Tennessee, and that he had been ordered not to leave the western district of Tennessee. The Defendant said that he did not understand why an officer was shining a flashlight in the car’s backseat and why he was being asked to step out of the car. The Defendant explained that he did not agree with Deputy Martinez’s recitation of the law or that Deputy Martinez had the authority to ask the Defendant to step out of his car for no reason. The Defendant said that he had been fighting a federal case since 2001 relative to his constitutional rights and that he believed an officer needed reasonable suspicion or probable cause before asking a driver to step out of a car. The Defendant explained that he got upset because Deputy Martinez kept telling him to step out of the car and that, as a result, he “t[ook] off.” The Defendant testified that he had “risked his freedom” to help his uncle build a house. The Defendant related that he was arrested in this case on November 30, 2023, and that he was supposed to be sentenced in federal court on December 5. The Defendant stated that he stopped his car so that his uncle could safely get out of the car, that he told his brother to get out, and that his brother also left the car. The Defendant said that he could see the patrol cars approaching from behind, that he kept watching the cars and not looking ahead at the road, and that by the time he looked ahead, he ran off the road and flipped his car. The Defendant testified that he wiggled out of his seatbelt, got out of the car, and ran through a field to flee. The Defendant said that he felt every Taser probe and that he had burn marks on his back and the backs of his legs. The Defendant also said that he sustained a black eye and broken teeth because of his fight with the officers. The Defendant explained that he broke his teeth when he “ate gravel” while fighting with Deputy Martinez on the ground. The Defendant related that he did not want to hurt anyone but that he wanted to get away. The Defendant said that he broke his wrist by struggling to pull out the Taser probes and that Deputy Martinez punched the Defendant’s face and not the Defendant’s shoulder. The Defendant testified that he reported wrist pain immediately after his arrest, that appropriate medical care for his wrist was delayed at the jail, and that he eventually had surgery to repair his wrist. The Defendant believed he was shot fifteen times with the Taser. On cross-examination, the Defendant testified that he dimmed his car’s headlights only after oncoming cars dimmed their headlights. The Defendant denied striking Deputy Martinez and maintained that Deputy Martinez was “coming at [him.]” The Defendant had no explanation for why his medical records from the emergency room failed to note a wrist injury but stated that he told the nurse that he had a hand injury. The Defendant stated that he had federal charges for the possession and distribution of methamphetamine but that he, personally, did not use methamphetamine. The Defendant admitted to fleeing by car and by foot and noted that “it escalated” and “should have never went that far.” The Defendant did not deny that the escalation was a result of his actions. -7-  The jury convicted the Defendant of evading arrest with a motor vehicle creating a risk of death or injury, reckless endangerment with a deadly weapon, and leaving the scene of an accident. He was sentenced to an effective two years in confinement. II Constitutional Issues The Defendant contends that the traffic stop was unconstitutional because it was pretextual in nature and because Deputy Martinez extended the stop beyond its original purpose. Additionally, the Defendant argues that the force used by law enforcement to effectuate his arrest violated both the Tennessee Constitution and the Constitution of the United States. The State responds that the Defendant has waived appellate review of these issues because he failed to raise them before the trial pursuant to Tennessee Rule of Criminal Procedure 12. A motion to suppress “must be raised before trial[,]” and “[u]nless the court grants relief for good cause, a party waives any defense, objection, or request by failing to comply with . . . rules requiring such matters to be raised pretrial[.]” T.R.C.P. 12(b)(2)(C), (f)(1). “The waiver provision of Rule 12 applies to issues embracing the constitutionality of statutes as well as the constitutional rights of the accused.” State v. Rhoden, 739 S.W.2d 6, 10 (Tenn. Crim. App. 1987) (citing State v. Farmer, 675 S.W.2d 212, 214 (Tenn. Crim. App. 1984); State v. Foote, 631 S.W.2d 470, 472-73 (Tenn. Crim. App. 1982)). This court has determined that “the appropriate remedy for an illegal arrest is the suppression of any evidence obtained as a result of the arrest.” State v. Morris, --- S.W.3d ---, No. E2025- 00041-CCA-R3-CD, 2026 WL 243358, at *11 (Tenn. Crim. App. 2026). Accordingly, challenges to the constitutionality of an arrest must be made by a pretrial motion to suppress or “a party waives [that] defense . . . by failing to comply with . . . rules requiring such matters to be raised pretrial.” T.R.C.P. 12(f)(1).1 Here, the Defendant failed to raise his constitutional claims in a pretrial motion to suppress his stop, detention, and ultimate arrest. The Defendant, however, argued at the trial that the traffic stop was unconstitutional and filed a motion for new trial in which he alleged that Deputy Martinez lacked constitutional grounds for the traffic stop. In its order denying the Defendant’s motion for new trial, the trial court faulted both parties, noting that the Defendant did not file a pretrial motion regarding his constitutional claims and that the State failed to object to the Defendant’s introduction of evidence at the trial regarding 1 Because Tennessee Rule of Criminal Procedure 12 uses the term “waiver,” we use that term. See State v. Baylis, --- S.W. ---, No. E2023-00886-SC-R11-CD, 2026 WL 3033430, at *6-7 (Tenn. 2026) (distinguishing between a waiver and a forfeiture). -8- the constitutionality of the traffic stop and arrest. Nevertheless, the court credited Deputy Martinez’s testimony and concluded that Deputy Martinez stopped the Defendant for a traffic violation, which constituted an “articulable basis for the [traffic] stop.” The court ultimately denied the Defendant’s constitutional claims for his failure to raise them in a pretrial motion. On appeal to this court, the Defendant, again, raises constitutional claims regarding his stop, detention, and arrest. The Defendant, however, did not file a reply brief or otherwise provide this court with any argument responding to the State’s waiver argument. See T.R.A.P. 27(c) (permitting an appellant to file a reply brief in response to relief sought by an appellee). The Defendant’s claims relating to the constitutionality of his traffic stop, detention, and arrest are waived for his failure to file a pretrial suppression motion. T.R.C.P. 12(b)(2)(C), (f)(1). III Sufficiency of the Evidence The Defendant contends that the evidence is insufficient to support his convictions. The State asserts that the evidence was sufficient to support the Defendant’s convictions. We agree with the State. In determining the sufficiency of the evidence, the standard of review is “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson v. Virginia, 443 U.S. 307, 319 (1979); see State v. Vasques, 221 S.W.3d 514, 521 (Tenn. 2007). The State is “afforded the strongest legitimate view of the evidence and all reasonable inferences” from that evidence. Vasques, 221 S.W.3d at 521. The appellate courts do not “reweigh or reevaluate the evidence,” and questions regarding “the credibility of witnesses [and] the weight and value to be given the evidence . . . are resolved by the trier of fact.” State v. Bland, 958 S.W.2d 651, 659 (Tenn. 1997); see State v. Sheffield, 676 S.W.2d 542, 547 (Tenn. 1984). “A crime may be established by direct evidence, circumstantial evidence, or a combination of the two.” State v. Hall, 976 S.W.2d 121, 140 (Tenn. 1998); see State v. Sutton, 166 S.W.3d 686, 691 (Tenn. 2005). “The standard of review ‘is the same whether the conviction is based upon direct or circumstantial evidence.’” State v. Dorantes, 331 S.W.3d 370, 379 (Tenn. 2011) (quoting State v. Hanson, 279 S.W.3d 265, 275 (Tenn. 2009)). The Defendant was convicted in Count 1 of evading arrest with a motor vehicle creating a risk of death or injury. “It is unlawful for any person, while operating a motor -9- vehicle on any street, road, alley or highway . . . to intentionally flee or attempt to elude any law enforcement officer, after having received any signal from the officer to bring the vehicle to a stop.” T.C.A. § 39-16-603(b)(1). The offense of evading arrest is a Class D felony where a person’s “flight . . . creates a risk of death or injury to innocent bystanders, pursuing law enforcement officers, or other third parties.” Id. § 39-16-603(d)(2)(B). Viewed in the light most favorable to the prosecution, the record reflects that the Defendant failed to dim his car’s headlights for approaching traffic and failed to maintain his lane of travel. Deputy Martinez testified that, after he stopped the Defendant’s car, the Defendant became “nervous,” put his car into gear, and drove away at a high rate of speed. Additionally, the Defendant acknowledged during his testimony that he attempted to flee and that he wanted to “get away.” Two passengers were in the car at the time, and one of them jumped out of the car while it was moving. The Defendant was driving on a curvy, two-lane road at a high rate of speed and his car flipped. Two patrol cars were in pursuit. We conclude that the evidence is sufficient for a jury to find beyond a reasonable doubt that the Defendant intentionally fled after being stopped by Deputy Martinez for a traffic violation and created a risk of death or injury to his passengers. The evidence is sufficient to support the conviction of evading arrest with a motor vehicle creating a risk of death or injury in Count 1. The Defendant is not entitled to relief on this issue. The Defendant was convicted in Count 3 of reckless endangerment with a deadly weapon. Reckless endangerment occurs when “[a] person . . . recklessly engages in conduct that places or may place another person in imminent danger of death or serious bodily injury.” See id. § 39-13-103(a). “Reckless endangerment committed with a deadly weapon is a Class E felony.” Id. at § 39-13-103(b)(1). “Reckless” refers to a person who “acts recklessly with respect to circumstances surrounding the conduct or the result of the conduct when the person is aware of but consciously disregards a substantial and unjustifiable risk that the circumstances exist or the result will occur.” Id. at § 39-11-302(c) (2025). “The risk must be of such a nature and degree that its disregard constitutes a gross deviation from the standard of care that an ordinary person would exercise under all the circumstances as viewed from the accused person’s standpoint.” Id. With regard to the imminent danger element, “[A]n injury is not imminent unless there is a ‘reasonable probability’ that it will occur.” State v. Rimmel, 710 S.W.3d 640, 649 (Tenn. 2025) (quoting State v. Payne, 7 S.W.3d 25, 28 (Tenn. 1999)). A motor vehicle may constitute a “deadly weapon” as that term is defined as “[a]nything that in the manner of its use or intended use is capable of causing death or serious bodily injury.” See T.C.A. § 39-11- 106(a)(6)(B); see also State v. Tate, 912 S.W.2d 785, 788-89 (Tenn. Crim. App. 1995) (citation omitted). Viewed in the light most favorable to the prosecution, the record reflects that the Defendant drove away from Deputy Martinez at a high rate of speed on a curvy, two-lane road with two passengers, one of whom exited the car while it was moving and was almost hit by a patrol car. The Defendant testified that while fleeing, he was not watching the road -10- and flipped his car. We conclude that the evidence is sufficient for a jury to find beyond a reasonable doubt that the Defendant recklessly engaged in conduct that placed others in imminent danger of death or serious bodily injury. The evidence is sufficient to support the conviction for reckless endangerment with a deadly weapon in Count 3. The Defendant is not entitled to relief on this issue. The Defendant was convicted in Count 7 of leaving the scene of an accident. If a vehicle is involved in an accident, “[t]he driver of that vehicle “shall immediately stop the vehicle at the scene of the accident or as close to the scene of the accident as possible or shall return to and in any event remain at the scene of the accident.” T.C.A. § 55-10-102. Viewed in the light most favorable to the prosecution, the record reflects that the Defendant’s car flipped over along the roadway and that the Defendant left his car and fled through a field until he was apprehended by the deputies. We conclude that the evidence is sufficient for a jury to find the Defendant guilty beyond a reasonable doubt of leaving the scene of an accident in Count 7. In reaching this conclusion, we have not overlooked the Defendant’s argument that the evidence is insufficient because Detective Martinez acknowledged that he did not have probable cause to stop the Defendant, who was never charged with any offenses related to his alleged conduct that precipitated to the stop, failure to maintain his lane and failure to dim his headlights. The Defendant argues that the “traffic stop turned into an illegal police investigatory fishing expedition that led to a dangerous high speed chase and ultimately [his] getting attacked by three police officers, tased excessively, and beaten until an ambulance came to the scene. Therefore, he reasons, the police conduct renders insufficient the evidence of the resulting crimes. Respectfully, we disagree. In reviewing a challenge to the sufficiency of the evidence to support a conviction, all evidence is considered, even if it was improperly admitted by the trial court. State v. Parker, --- S.W.3d ---, ---, n.27, 2026 WL 2564584, at *13, n.27 (Tenn. 2026); State v. Franklin, 585 S.W.3d 431, 457 (Tenn. Crim. App. 2019). “This is true even if the reason the evidence was erroneously admitted is the result of the denial of a defendant’s constitutional rights which results in a reversal of the conviction and granting a new trial.” Id. The rule likewise “applies when the conviction is reversed because of trial proceedings in violation of an accused’s constitutional rights[.]” Id. In accord with these principles, our review has encompassed all of the evidence, without regard to the Defendant’s arguments that it was obtained in violation of his constitutional rights and therefore was inadmissible at the trial. The Defendant is not entitled to relief on this issue. IV -11-  Cumulative Error Doctrine The Defendant asserts that the cumulative effect of multiple trial errors resulted in a deprivation of his right to a fair trial. Specifically, the Defendant argues that errors by HCSD resulted in his being arrested illegally, being brutally beaten, and receiving an unfair trial and that each of these individual errors combine together to create cumulative error. The State counters that this claim is waived because the Defendant did not raise it in his motion for new trial, and, alternatively, because the Defendant failed to establish that the trial court committed any errors. The cumulative error doctrine requires relief when “multiple errors [are] committed in trial proceedings, each of which in isolation constitutes mere harmless error, but which when aggregated, have a cumulative effect on the proceedings so great as to require reversal in order to preserve a defendant’s right to a fair trial.” State v. Hester, 324 S.W.3d 1, 76-77 (Tenn. 2010) (internal citations omitted); see State v. Jordan, 325 S.W.3d 1, 79 (Tenn. 2010) (“‘[T]he combination of multiple errors may necessitate . . . reversal . . . even if individual errors do not require relief.’”) (quoting State v. Cribbs, 967 S.W.2d 773, 789 (Tenn. 1998)). However, “the failure to raise cumulative error in the motion for new trial waives the issue on appeal.” State v. King, 703 S.W.3d 738, 787 (Tenn. Crim. App. 2024). As the Defendant did not raise cumulative error in his motion for new trial, the issue is waived. Accordingly, the Defendant is not entitled to relief on this basis. In consideration of the foregoing and the record as a whole, the judgments of the trial court are affirmed. s/Robert H. Montgomery, Jr. _ ____ ROBERT H. MONTGOMERY, JR., JUDGE -12-