State v. Patterson
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At issue in this appeal was what showing, if any, a defendant must make to prevail on a motion for reduction of sentence under Tenn. R. Crim. P. 35 where the defendant pleaded guilty without an agreement as to sentencing pursuant to Tenn. R. Crim. P. 11(c)(1)(B).
Defendant pleaded guilty without an agreement as to sentence. The trial court granted Defendant’s Rule 35 motion and reduced his aggregate sentence. The Court of Criminal Appeals reversed, concluding that a defendant must present post-sentencing information or developments warranting a reduction of sentence to prevail on a Rule 35 motion. The Supreme Court reversed and reinstated the trial court’s judgment, holding (1) the standard applied by the Court of Criminal Appeals is limited to Rule 35 motions seeking reduction of specific sentences imposed in exchange for guilty pleas; and (2) the trial court did not abuse its discretion when it determined that Defendant’s initial sentence was excessive and granted Defendant’s Rule 35 motion.
Court Description:
Authoring Judge: Justice Cornelia A. Clark
Trial Court Judge: Judge David A. Patterson
We granted this appeal to determine what showing, if any, a defendant must make to prevail on a motion for reduction of sentence under Rule 35 of the Tennessee Rules of Criminal Procedure, where the defendant pleaded guilty without an agreement as to sentencing, pursuant to Tennessee Rule of Criminal Procedure 11(c)(1)(B). The Court of Criminal Appeals held that a defendant must present post-sentencing information or developments warranting a reduction of sentence to prevail on a Rule 35 motion. We disagree and limit this standard to Rule 35 motions seeking reduction of specific sentences imposed in exchange for guilty pleas, pursuant to Tennessee Rule of Criminal Procedure 11(c)(1)(C). Accordingly, we reverse the judgment of the Court of Criminal Appeals and reinstate the trial court s judgment granting the defendant s Rule 35 motion and reducing his aggregate sentence.
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