State of Tennessee v. Blaze Valentino Burkett, M2019-02143-CCA-R3-CD

Burkett pled guilty to one count of possession of ≥0.5g methamphetamine with intent to sell (Class B); ten-year sentence suspended after serving one year; released Jan 14, 2019 and placed on probation.
He reported and tested negative during early supervision and made regular payments; probation officer described him as “exceptional” until May 2019.
On May 7, 2019, Burkett was arrested after attempting to break into his father’s home, threatening officers with a tire iron, and later booked with several charges including possession of methamphetamine and introduction of contraband into a penal facility.
On May 28, 2019, while in custody at court, Burkett escaped the holding area and was recaptured; an amended violation charge for escape was added.
At the Nov. 14, 2019 revocation hearing, officers’ testimony was credited, Burkett admitted renewed meth use and the escape, the trial court found probation violations by a preponderance of the evidence and ordered him to serve the remainder of his ten-year sentence.
Burkett appealed, arguing the trial court abused its discretion by fully revoking probation instead of imposing a treatment-oriented alternative; the Court of Criminal Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by fully revoking probation for alleged new criminal conduct	State: Officer testimony and defendant’s admissions (including escape) provided sufficient proof by a preponderance to revoke	Burkett: Revocation was an abuse; he should receive an alternative (split confinement + inpatient treatment) due to meth-induced delusions and addiction	Court: No abuse of discretion; substantial evidence supported violations and revocation affirmed
Whether the court erred by refusing an alternative sentence/treatment instead of full incarceration	State: Defendant not entitled to a second grant of probation; violent conduct and escape justified confinement; treatment may be provided in custody	Burkett: Needed inpatient rehab in the community to address severe meth addiction	Court: Trial court acted within authority; defendant not entitled to another alternative; confinement appropriate

State v. Mitchell, 810 S.W.2d 733 (Tenn. Crim. App. 1991) (trial court assesses witness credibility at revocation hearings)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (standard for reviewing probation revocation; must be supported by substantial evidence)
State v. Grear, 568 S.W.2d 285 (Tenn. 1978) (probation revocation standard requiring substantial evidence)
State v. Delp, 614 S.W.2d 395 (Tenn. Crim. App. 1980) (same)
State v. Farrar, 355 S.W.3d 582 (Tenn. Crim. App. 2011) (discussion of revocation review and standards)
State v. Shaffer, 45 S.W.3d 553 (Tenn. 2001) (abuse of discretion explained in sentencing/revocation context)
State v. Moore, 6 S.W.3d 235 (Tenn. 1999) (analysis of trial court discretion and review standards)
State v. Kendrick, 178 S.W.3d 734 (Tenn. Crim. App. 2005) (revocation is within trial judge’s sound discretion)