State of Tennessee v. Claude David Powers, M2016-02019-CCA-R3-CD

Defendant Claude David Powers pleaded guilty to aggravated assault (Class C felony) pursuant to a plea agreement that dismissed attempted first-degree murder; the trial court reserved sentencing.
Presentence report showed multiple prior convictions (DUI, public intoxication, assault, vandalism, resisting arrest), two prior probation violations, substance abuse history, and current Suboxone treatment.
Victim testified Powers stabbed him multiple times after a dispute at a residence where drugs and alcohol were present; Powers’ written statement claimed he acted in self-defense during a struggle after being threatened with a knife.
Trial court found no applicable enhancement or mitigating factors, described the offense as possibly drug-related, and imposed a four-year Range I sentence with one year to serve in confinement and the balance on probation.
Defendant appealed, arguing the sentence was excessive and that the court erred by denying full probation; appellate court found the trial court failed to state adequate findings or apply sentencing principles on the record and remanded for a new sentencing hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the four-year sentence and split confinement were excessive	State: Sentence within statutory range and presumptively reasonable	Powers: Sentence excessive given background, rehab potential, and request for full probation	Sentence vacatur/remand for new sentencing hearing because trial court failed to state findings required by law
Whether the trial court erred by denying full probation	State: No error; court properly exercised discretion	Powers: Eligible and suitable for full probation; trial court did not apply sentencing principles	Court reversed and remanded because record lacks required analysis of probation factors
Whether trial court applied enhancement/mitigating factors properly	State: Court found none applied	Powers: Court failed to explain or apply factors on record	Remand required; court did not make required findings to permit appellate review
Whether the record supports presumption of reasonableness under Bise	State: Sentence within-range so presumptively reasonable	Powers: Lack of stated reasons prevents presumption	Presumption withheld; remand for resentencing so reasons and findings are placed on the record

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (standard for appellate review of within-range sentences and presumption of reasonableness)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (factors and evidence trial court must consider at sentencing)
State v. Moss, 727 S.W.2d 229 (Tenn. 1986) (sentencing hearing considerations and record requirements)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (standard of review for probation decisions)
State v. Souder, 105 S.W.3d 602 (Tenn. Crim. App. 2002) (burden on defendant to show suitability for probation)
State v. Trotter, 201 S.W.3d 651 (Tenn. 2006) (when confinement may be justified for probation-eligible defendants)