State of Tennessee v. Christine Caudle

Summary

The Tennessee Supreme Court held that the abuse of discretion standard of review, accompanied by a presumption of reasonableness, applies to within-range sentences reflecting a proper application of the purposes and principles of the Sentencing Act, including decisions granting or denying probation or any other alternative sentence. It further held that the absence of a guilty plea hearing transcript does not per se preclude merits review: the Court of Criminal Appeals must decide case-by-case whether the record permits meaningful review, and if it does, review proceeds with a presumption that the missing transcript would support the trial court's ruling. Applying those rules, the Court found the record adequate and affirmed the concurrent three-year Range II sentences and the denial of probation for a defendant who dragged a store loss-prevention officer behind a getaway vehicle while on probation for a prior theft.