State of Tennessee v. Andrew Boykin, W2016-01055-CCA-R3-CD

Andrew Boykin pled guilty (blind plea) to possession of ≥0.5g cocaine with intent to sell, possession with intent to deliver, possession of drug paraphernalia, criminal impersonation, and evading arrest; the two cocaine convictions were merged.
Arrest facts: officers stopped a vehicle for no headlights; Boykin (front-seat passenger) gave a false name, was seated with a brown bag containing a digital scale, 4.1 grams powder cocaine, and a photo of Boykin; he fled but was caught and had $240 on him.
Presentence report: age ~30, GED, intermittent employment, daily cocaine and marijuana use with no prior drug treatment, prior felony for introducing a communication device into a penal institution, on probation at the time of the instant offenses, and multiple juvenile adjudications.
Trial court applied four enhancement factors (prior criminal behavior, failure to comply with community-release conditions, on probation at offense, juvenile adjudications) and two mitigating factors (no serious bodily injury; employment history).
Sentences: Range I standard offender; ten years for possession of cocaine (merged counts), concurrent county jail sentences for misdemeanors; court denied alternative sentencing and ordered confinement in TDOC.

Issue	Plaintiff's Argument (Boykin)	Defendant's Argument (State)	Held
Whether the ten-year sentence is excessive	Trial court erred; record did not support more than minimum (8 years)	Sentence supported by enhancement factors and discretion	Affirmed — no abuse of discretion; appellant failed to show impropriety
Whether alternative (suspended) sentence with long-term inpatient rehab should be ordered	Boykin sought suspension and long-term inpatient drug treatment in lieu of incarceration	Denial appropriate given criminal history, probation at time of offense, and lack of prior treatment	Affirmed — denial of alternative sentencing not an abuse of discretion
Applicability/weight of enhancement and mitigating factors	Requested greater weight for mitigation (treatment potential, employment)	Court relied on enhancement factors (prior record, probation, juvenile adjudications, failure to comply with release)	Trial court properly applied factors; appellate review defers to trial court discretion
Standard of appellate review for sentence	N/A (challenging sentence as excessive)	Sentences reviewed for abuse of discretion with presumption of reasonableness	Affirmed under abuse-of-discretion standard (Bise/Caudle framework)

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate standard: abuse of discretion with presumption of reasonableness for sentences)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (applies Bise standard to alternative sentencing)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (sentencing factors and considerations)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (trial court’s weighing of enhancement/mitigating factors committed to discretion)
State v. Zeolia, 928 S.W.2d 457 (Tenn. Crim. App. 1996) (criteria for denying alternative sentencing)