State v. Marty Allison Hobdy, Jr.
Court: Tennessee Court of Criminal Appeals Docket: M2025-00654-CCA-R3-CD Filed: February 20, 2026 County: Sumner County Outcome: Probation revocation reversed
N. Cate Law defends probation violations in Tennessee across Davidson County and Middle Tennessee. Free consultation: (615) 664-8083.
The Holding
A Sumner County probation revocation was reversed because the State offered no proof at the revocation hearing. Instead, the trial court relied on its own memory of testimony from an earlier trial in which the defendant had been acquitted. The Court of Criminal Appeals held that this collapsed the trial court’s role as a neutral and detached decisionmaker and violated fundamental fairness.
Why It Matters
Probation revocation hearings have a lower burden of proof than criminal trials, but they are not lawless proceedings. The State has to put on evidence. The trial court has to act as a neutral and detached decisionmaker, not as a fact-witness recalling testimony from a prior proceeding the defendant won.
Hobdy is the strongest 2026 Middle Tennessee authority for probation-revocation defense. The opinion’s “neutral and detached decisionmaker” language travels well — quote it whenever the State tries to relitigate facts the defendant was acquitted of, or when the trial court announces what it “already knows” from prior hearings.
If you or a loved one is facing a Tennessee probation revocation in Sumner, Davidson, Williamson, Rutherford, or Wilson County, this case is required reading for whoever is defending you.
Statute / Rule References
Tenn. Code Ann. § 40-35-311 (probation revocation); Fourteenth Amendment due process
Read the Opinion
You can find the full opinion on the Tennessee Courts website. Search the Tennessee Court of Criminal Appeals 2026 opinions index by docket number M2025-00654-CCA-R3-CD.
Charged with a Tennessee Criminal Case?
I’m Nathan Cate. I defend criminal cases in Davidson, Williamson, Rutherford, Sumner, Wilson, and Maury Counties. If your case touches the issues above — or any other Tennessee criminal matter — call (615) 664-8083 for a free consultation. I’ll review the charging document, run the procedural posture, and tell you what your case actually looks like.
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This is a summary of a published opinion, not legal advice. Holdings cited may evolve as later cases distinguish or overrule them. If you have a pending case that touches one of these issues, contact N. Cate Law for case-specific guidance.
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