State of Tennessee v. Craig Dagnan, 641 S.W.3d 751

Background:

Craig Dagnan pleaded guilty to theft (>$1,000, < $10,000) and received a six‑year Range II sentence with most suspended to supervised probation.
Over ~4 years he incurred four prior partial revocations (short local confinement terms) for probation violations (missed payments, failed drug screens, new charges, absconding, etc.).
After a furlough to a treatment facility, Dagnan was discharged and failed to report back to jail; a fifth revocation petition alleged absconding and new Georgia charges.
At the December 2019 revocation hearing the trial court found a probation violation by a preponderance, conducted a two‑part analysis, and fully revoked probation, ordering Dagnan to serve the balance of his six‑year sentence in TDOC.
The Court of Criminal Appeals affirmed; Dagnan appealed to the Tennessee Supreme Court arguing (among other things) that courts inconsistently treat revocation as a one‑step vs. two‑step process and that appellate review was inadequate.
The Tennessee Supreme Court affirmed the revocation and clarified that probation revocation involves two discrete discretionary decisions and set the applicable standard of review.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation proceedings are one‑step or two‑step	State: Trial court decisions are within existing statutory framework; no separate hearing required	Dagnan: Courts are inconsistent; the decision to revoke and the choice of consequence are distinct and must be treated separately on appeal	Two‑step process: (1) whether probation was violated; (2) what consequence to impose. Both are discrete discretionary decisions.
Standard of appellate review for revocation/consequence	State: Review for abuse of discretion	Dagnan: Appellate review is meaningless without required findings; sought more searching review or required findings	Abuse of discretion with a presumption of reasonableness applies if the trial court places sufficient findings and reasons on the record; otherwise de novo review or remand may be appropriate.
Whether trial court must hold a separate hearing or make additional findings before imposing a consequence	State: No statutory requirement for a separate hearing; existing revocation hearing suffices	Dagnan: Trial courts should be required to make findings on the record to allow meaningful appellate review	No additional hearing is required; trial court must, however, articulate sufficient factual findings/reasons on the record for both steps so appellate review is meaningful.
Application to this case—did the trial court abuse its discretion in ordering incarceration?	State: Trial court properly considered prior violations, seriousness and absconding; incarceration appropriate	Dagnan: He was wrongfully discharged from treatment and accepted elsewhere; consequence was too harsh	No abuse of discretion. The trial court’s oral findings (multiple revocations, deliberate failure to report, addiction history) supported full revocation and incarceration; Court affirms.

Key Cases Cited

State v. Beard, 189 S.W.3d 730 (Tenn. Crim. App.) (probation may be revoked on preponderance of evidence)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (adopted abuse‑of‑discretion review with presumption of reasonableness for sentencing)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (extended Bise standard to alternative sentencing)
State v. Pollard, 432 S.W.3d 851 (Tenn. 2013) (presumption of reasonableness requires trial court articulation of reasons)
State v. King, 432 S.W.3d 316 (Tenn. 2014) (trial court must place reasons on record to preserve presumption of reasonableness)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (abuse of discretion standard cited for revocation review)
State v. Hunter, 1 S.W.3d 643 (Tenn. 1999) (statutory alternatives available after revocation)
State v. Phelps, 329 S.W.3d 436 (Tenn. 2010) (discussing abuse of discretion and appellate review principles)
State v. Reams, 265 S.W.3d 423 (Tenn. Crim. App.) (citing abuse of discretion standard in revocation context)