State of Tennessee v. Daniel Edrick Lutrell, W2016-01947-CCA-R3-CD

On April 4, 2015 Lutrell attempted to pass vehicles in a no-passing zone at high speed, collided head-on with an oncoming car, and caused the death of the driver (Darius Traylor) and injuries to a minor passenger.
Lutrell admitted he had consumed some alcohol earlier; blood alcohol was .079 and an open container was in his car. He estimated driving 70–75 mph while passing.
Indicted for two counts vehicular homicide, reckless aggravated assault, improper passing, DUI and DUI per se; pled guilty to vehicular homicide (substantial risk), reckless aggravated assault, and passing in a no-passing zone; remaining counts dismissed.
At sentencing, trial court considered presentence report, victim harm, Lutrell’s military service and employment, prior traffic convictions, and post-offense convictions; found enhancement for prior criminal behavior and multiple victims and mitigation for good work history.
Trial court imposed concurrent within-range sentences: 6 years (vehicular homicide), 4 years (reckless aggravated assault), and 30 days (misdemeanor passing with 75% service eligibility), denied probation, and ordered confinement primarily to avoid depreciating the seriousness of the offense and for deterrence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether maximum within-range felony sentences were proper	State: sentences within statutory ranges and supported by enhancement factors	Lutrell: trial court abused discretion by imposing maximum (6 years)	Affirmed — within-range sentences reasonable and supported by record under sentencing principles (no abuse of discretion)
Whether misdemeanor sentence (30 days, 75% served) was proper	State: authorized by statute and supported by enhancements	Lutrell: challenges proportionality/appropriateness	Affirmed — misdemeanor sentence authorized and not an abuse of discretion
Whether denial of probation and order of confinement was proper	State: confinement appropriate to avoid depreciating seriousness and to deter others	Lutrell: trial court relied improperly on deterrence and failed to apply Hooper factors	Affirmed — trial court cited multiple statutory grounds (seriousness, deterrence, multiple victims), record supports denial; heightened review not required
Whether trial court failed to state adequate reasons on the record	State: court articulated factors and reasons at sentencing	Lutrell: claimed inadequate consideration/application of sentencing principles	Affirmed — trial court stated findings and applied purposes/principles of Sentencing Act; presumption of reasonableness applies

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse-of-discretion standard with presumption of reasonableness for within-range sentences)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (trial court’s discretion to select any sentence within range consistent with Sentencing Act)
State v. Hooper, 29 S.W.3d 1 (Tenn. 2000) (heightened review where denial of probation is based solely on one factor such as deterrence or avoiding depreciation)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (abuse-of-discretion standard with presumption of reasonableness applies to probation decisions)
State v. Pollard, 432 S.W.3d 851 (Tenn. 2013) (abuse-of-discretion with presumption of reasonableness is appropriate standard for sentencing decisions)