State v. Tommy Lynn Hollingsworth
Court: Tennessee Court of Criminal Appeals Docket: W2025-00442-CCA-R3-CD Filed: March 11, 2026 County: Henderson County Outcome: Revocation affirmed on one count; reversed on a count where sentence had already expired
The Holding
A multi-count probation revocation was reversed in part. The Court of Criminal Appeals held that one count’s revocation was reversible because the underlying sentence on that count had already expired before the revocation hearing.
Why It Matters
Trial courts and prosecutors sometimes try to revoke probation on a sentence that has already finished running. They can’t. If the underlying sentence has expired, the trial court has no jurisdiction to revoke.
This is a procedural lesson that applies statewide. For families of Tennessee defendants facing multi-count probation revocations, the math matters: every count has its own sentence, and every sentence has its own expiration date. Always run the expiration math on every count before conceding revocation jurisdiction.
If your loved one is facing revocation across multiple counts, your defense lawyer should be checking the calendar — count by count — before the hearing.
Statute / Rule References
Tenn. Code Ann. § 40-35-311 (revocation jurisdiction)
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 W2025-00442-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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