In my words
You don’t have to take my word for any of this. Here are the State’s own papers, side by side, saying two different things. Every one is from a police report, a lab report, a court order, a docket or the State’s own brief.
Donyell Dewayne Holland
25 places where the record contradicts itself
1The prosecutor’s letter vs. the police report: who knew about Brown’s proffer
One paper saysThe State’s April 8, 2024 letter to defense counsel: “We did not learn of the proffer until the day before.”
Another paper saysDet. Stokes’s supplement: Brown’s November 1, 2021 proffer was attended by two assistant district attorneys from the same office (Leslie Longshore and Colin Campbell), a federal prosecutor and an ATF agent.
Source: State letter 4/8/2024; Stokes Supplement CA
2“Brown has entered a guilty plea” before the plea existed
One paper saysThe same April 8, 2024 letter: “Brown has entered a guilty plea to his federal charges.”
Another paper saysBrown’s federal plea agreement (Doc. 80, 1:21-cr-00001) is file-stamped September 13, 2024, five months later and after he testified.
Source: State letter 4/8/2024; Doc. 80
3The NIBIN gun lead nobody could find
One paper saysAn ATF NIBIN lead linking a gun in this case to another shooting was created June 11, 2020.
Another paper saysOn September 29, 2022 an assistant DA emailed: “I am just checking to make sure there are no NIBIN Reports as there are none in the case file.” Donyell’s pro se discovery motions had been denied July 13, 2021.
Source: ATF NIBIN lead 6/11/2020; email 9/29/2022; rule docket
4“Only this gun” vs. the State’s own firearms examiner
One paper saysState’s appeal brief, page 21: the bullet “could only have been shot out of the red SCCY pistol.”
Another paper saysTBI firearms report (Exhibit 53): the bullet “bears the same class characteristics” and “the damaged condition of the bullet ... precludes a more conclusive determination.”
Source: State’s Br. 21; TBI Ex. 53
5An evidence inventory dated before its own entries
One paper saysEvery page of Evidence Inventory 20-052168 is stamped “Report By Inv McElroy 634, Date & Time 6-17-20 @ 1113.”
Another paper saysThe same pages carry entries dated August 3, 2020 and October 1, 2020. The original ends at Item 176, “END OF REPORT.” The version “Updated 10-2-20” adds Item 177. Items 178 to 180 are missing.
Source: Evidence Inventory 20-052168, both versions
6Item 177 described two different ways
One paper saysInventory: “97 live ‘TW 69’ rounds on a desintirating belt. Trunk of a Pontiac Grand AM registered to Randall Leslie.”
Another paper saysCSU follow-up report: a “plastic bag in the trunk with numerous live rifle rounds.” The Grand Am went to Precision Towing on June 3, 2020 and was processed October 1, 2020, with no seal or hold record in between.
Source: Inventory; McElroy follow-up report; tow record
7Gloves sworn to be in police custody before police had them
One paper saysSearch warrant affidavits, paragraph 6: “3 pair of gloves ... All the items located ... are in Chattanooga Police custody.”
Another paper saysInventory items 1 to 4 (May 29, 2020) hold no gloves. Gloves first appear as items 129, 130 and 134, from the Lancer, on June 13, 2020. No glove was ever tested.
Source: Affidavits ¶6; Evidence Inventory
8Brown’s 9mm: four stories of where it came from
One paper saysStokes’s initial report, in Brown’s words: “under the passenger seat.” Officer Shelor: “under the driver seat.”
Another paper saysThe search warrant affidavit says a relative of Randall’s mother found it. The federal indictment says it was “seized from Derik Adam Brown on May 28, 2020.”
Source: Stokes initial report; Shelor report; affidavit ¶6; federal Doc. 1
9The murder weapon’s box was in Randall’s own bedroom
One paper saysInventory item 24: the State’s murder weapon is an SCCY pistol, serial 637445.
Another paper saysInventory item 154: “Box for SCCY Pistol, Serial 637445 ... under the dresser,” at Randall Leslie’s apartment, 5113 Highway 58.
Source: Evidence Inventory items 24 and 154
10The bullet in the wall at Teakwood never went to the lab
One paper saysCSU initial report: “A bullet projectile was located in the sheetrock behind the door” at Teakwood (inventory item 7).
Another paper saysNo Teakwood bullet appears in any of the three TBI reports.
Source: Johnson CSU report; TBI reports
11The back seat where the State says he died was never examined
One paper saysCSU report: “the possibility of blood on the back seat and seat belts.”
Another paper saysTBI, December 15, 2022: “023-a Rear seat ... No examination was performed.”
Source: McElroy report; TBI report 12/15/2022
12The victim reference sat in the lab untested
One paper saysStokes obtained a DNA reference from Randall’s mother on June 15, 2020.
Another paper saysTBI, October 30, 2020: “010-a Elimination swabs from Cherie Harden ... No examination was performed,” while the same report asks police to “submit a victim ... standard.”
Source: TBI report 10/30/2020
13A stolen police gun in the evidence, theft report missing
One paper saysNCIC, June 10, 2020, on Smith & Wesson SD40VE FZJ3685: “STOLEN GUN ... OCA/18-125302 ... ORI IS CHATTANOOGA PD.”
Another paper saysReport 18-125302 is not in the file.
Source: NCIC printout 6/10/2020
14“Neighborhood information” that named a house no one named
One paper saysStockton affidavit, paragraph 10: “Mr. Leslie was shot inside 4088 Teakwood Drive and transported to 6305 Stockton Drive.”
Another paper saysBlount’s June 3, 2020 entry of the same family information: a house “off Bonny Oaks Drive then taken to an unknown location in Georgia,” and officers “did not believe there was enough probable cause.”
Source: Stockton affidavit ¶10; Blount entry 6/3/2020
15One interview, three different clocks
One paper saysKiara Carson’s June 8, 2020 interview: the interview-room video clock reads about 4:02 PM; the affidavit says “approximately 1606 hours.”
Another paper saysStokes’s initial report puts the same interview at “approximately 1846,” after 6:30 PM.
Source: Disc 5; affidavit ¶8; Stokes initial report
16Sworn testimony about blood the lab says wasn’t there
One paper saysAt trial Lanham testified Randall bled “a lot” in the camper (as quoted in the State’s brief, p. 27).
Another paper saysTBI (Exhibit 49): “The items tested from the camper did not indicate the presence of blood.” The State’s brief concedes it.
Source: State’s Br. 27; TBI Ex. 49
17Reports approved while the star witness was still being interviewed
One paper saysSgt. V. Miller approved the Conry supplement at 10:42 AM and the Stokes proffer supplement at 10:43 AM on December 9, 2021.
Another paper saysBrittany Lanham’s interview-room clock that morning runs from 10:10 AM to 11:52 AM.
Source: Supplement approval stamps; Disc 14
18The State’s own witness report vs. the State’s brief
One paper saysDet. Gunn’s Supplement 4: Lauren Delaney came on her own; Brittany told her Randall “was shot inside the camper”; Holland told her “he didn’t shoot LESLIE.”
Another paper saysThe State’s appeal brief: “Lauren’s last name is not in the record.”
Source: Gunn Supplement 4; State’s brief
19No one is named as finding the body
One paper saysAutopsy MEC20-2121: the body was “discovered ... by law enforcement.”
Another paper saysNo finder is named, and no Marion County recovery report, scene log or scene photographs are in any version of the file.
Source: Autopsy MEC20-2121; discovery file
20Arraigned five weeks after judgment
One paper saysOrder of November 21, 2024: “This cause came before the Court on November 21, 2024 upon arraignment of the Defendant ... the Defendant enters a plea of Not Guilty,” made “nunc pro tunc” to April 10, 2024.
Another paper saysThe judgments were entered October 25, 2024. The docket for November 21, 2024 shows no hearing, no transport and no appearance.
Source: Order 11/21/2024; rule docket 317210
21The clerk’s docket says life without parole; the court papers say life
One paper saysDocket, October 25, 2024: “LIFE WITHOUT THE POSSIBLITY OF PAROLE.”
Another paper saysThe State’s own June 7, 2024 response: “The State did not seek the punishment of life imprisonment without the possibility of parole.” The Count 2 judgment form checks “Life.”
Source: Rule docket 10/25/2024; State response 6/7/2024; judgment
22“No prejudice” in April, “fast-approaching trial” in November
One paper saysApril 23, 2024: the defense motion to continue is denied (“the witness list remained the same”).
Another paper saysNovember 22, 2024 order finding the case extended and complex: “counsel had to prepare quickly and thoroughly for the fast-approaching jury trial.”
Source: Rule docket 4/23/2024; order 11/22/2024
23A lawyer still listed after Donyell was on his own
One paper saysDonyell proceeded pro se after counsel’s withdrawal was granted August 16, 2024.
Another paper saysThe live docket listed “Attorney: MACNEILL JR, DAVID W” from November 21, 2024 to about April 15, 2025, the whole time his pro se motions sat, with no order removing him.
Source: Rule docket 317210
24“Each of the grounds” vs. “I’m not seeing it”
One paper saysJuly 14, 2025 order denying the motion for new trial “on the merits as to each of the grounds requested.”
Another paper saysAt the June 13, 2025 hearing (p. 11) the court said each issue would be judged (“They will. They will.”) and then: “I’m not seeing in the motions for new trial where issuance of a search warrant is raised as an issue.”
Source: Order 7/14/2025; MNT transcript 6/13/2025
25The shots-fired call: two report numbers, no video
One paper saysOfficer Gerity’s memo on the May 27, 2020 6:35 PM call is numbered 20-051755, with in-car video “No” and body camera “No.”
Another paper saysStokes’s initial report cites the same call as 20-052155.
Source: Memo 20-051755; Stokes initial report
These are the contradictions proven from documents alone. More come from recorded interviews and will be added after each recording is checked by ear against the audio.
In pictures
