State v. Lawrence Darrell Patton
Court: Tennessee Court of Criminal Appeals Docket: M2024-01634-CCA-R3-CD Filed: January 30, 2026 County: Lewis County Outcome: Revocation affirmed; confinement order reversed and remanded
The Holding
A Lewis County probation revocation was affirmed, but the trial court’s order of full confinement was reversed and remanded for new sentencing. The Court of Criminal Appeals held that a trial court must analyze the disposition decision (full confinement vs. modified sentence) on the record after revoking — it is not enough to simply revoke and impose the balance of the sentence in custody.
Why It Matters
Even when a probation violation is established, the question of what to do about it is a separate decision the trial court must explain. Many trial courts treat revocation and disposition as a single step — “violation found, balance to TDOC” — without addressing whether modified terms, split confinement, or community corrections might be appropriate.
Patton is reversal authority for that exact pattern. Even when the revocation itself stands, the disposition order can be reversed for lack of on-the-record analysis. That is potentially a second bite at avoiding full confinement after a violation has already been found.
For families of Tennessee clients facing the disposition phase of a revocation hearing, this is the kind of case your defense lawyer should know.
Statute / Rule References
Tenn. Code Ann. § 40-35-311 (revocation); Tenn. Code Ann. § 40-35-310 (disposition options after revocation)
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 M2024-01634-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.
N. Cate Law 222 2nd Avenue North, Suite 220 Nashville, TN 37201 catelaw.com · Sentencing & Petition to Suspend
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.
#NashvilleCriminalLawyer #TennesseeCriminalAppeal #Probation #Revocation #Sentencing