State of Tennessee v. Christopher Hinson, W2024-00236-CCA-R3-CD

Christopher Hinson pled guilty to domestic assault and attempted aggravated burglary against his wife, Sherrie Hinson, and was sentenced to concurrent custodial terms, suspended to supervised probation with a strict no-contact condition.
Shortly after sentencing, Hinson allegedly violated the no-contact order by persistently messaging, calling, and surveilling the victim and her property, as well as contacting her relatives and neighbors.
A probation officer submitted a violation report not long after probation began, confirming Hinson's failure to comply despite explicit warnings about the order's strictness.
Hinson sought entry into a rehabilitation program as an alternative to incarceration after the violation was raised, but the State requested full revocation of probation.
The trial court found Hinson had violated probation terms and fully revoked probation, reinstating the original custodial sentence, citing the recency and seriousness of the violation, and the risk posed to the victim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by revoking probation fully and reinstating incarceration	Did not consider alternatives to incarceration	Sought rehabilitation program, argued for partial revocation	No error; court fully revoked probation
Whether sufficient findings were made on the record for revocation	Findings and reasons not adequately stated on record	Argued for required clarity and specifics	Sufficient findings; no abuse of discretion

North Carolina v. Alford, 400 U.S. 25 (1970) (recognizing the validity of "best interest" guilty pleas without admitting guilt)
State v. Shaffer, 45 S.W.3d 553 (Tenn. 2001) (stating the abuse of discretion standard for probation revocation)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (discussing evidentiary standards in probation revocation)
State v. Hunter, 1 S.W.3d 643 (Tenn. 1999) (explaining trial court's discretion regarding consequences of revocation)