STATE OF TENNESSEE v. RICHARD DARAN ANGEL - Articles

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STATE OF TENNESSEE v. RICHARD DARAN ANGEL

Posted by: Azya Thornton on Feb 9, 2026

Court: TN Court of Criminal Appeals

Attorneys 1: Jonathan Skrmetti, Attorney General and Reporter; Benjamin A. Ball, Senior Assistant Attorney General; Christopher R. Stanford, District Attorney General; and Matthew T. Colvard, Assistant District Attorney General, for the appellant, State of Tennessee.

Attorneys 2: Kendall Stivers Jones, Assistant Public Defender – Appellate Division, Franklin, Tennessee; William L. Cathcart, Assistant Public Defender, McMinnville, Tennessee, for the appellee, State of Tennessee.

Judge(s): EASTER

Defendant, Richard Daran Angel, was indicted for one count of theft by home improvement in an amount of $10,000 or more but less than $60,000. Before trial, Defendant moved to dismiss the indictment, arguing that the contractor fraud statute, Tennessee Code Annotated section 39-14-154, was unconstitutionally vague, both on its face and as applied to him. After a hearing, the trial court granted Defendant’s motion and entered an order dismissing the indictment. The State appeals, arguing that the trial court erred in determining that the contractor fraud statute was unconstitutionally vague at the pretrial stage because Defendant could not show that the statute was vague as applied to him. After review, we agree with the State and reverse and remand the judgment of the trial court.

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