State of Tennessee v. Daniel Leon McCaig, W2021-00736-CCA-R3-CD

Daniel McCaig pled guilty in 2018 to three counts of selling methamphetamine and received concurrent eight‑year sentences to be served on Community Corrections.
He had a prior 2007 conviction for attempted aggravated sexual battery and was subject to lifetime sex‑offender community supervision.
In August 2020 the court partially revoked his alternative sentence, ordered TDOC supervision of the balance, and gave jail credit for time served.
In 2021 McCaig was arrested in February (large quantity of meth, scales, cash, and a loaded firearm found near his person/vehicle) and again in May (domestic incidents, violation of protection order, and possession of a knife/brass‑knuckle weapon); two probation violation reports followed.
After a June 1, 2021 hearing the trial court found a probation violation by a preponderance of the evidence, revoked McCaig’s probation in full, and ordered him to serve the eight‑year sentence; McCaig appealed claiming the court failed to consider alternatives and make required findings under controlling precedent.
On de novo review the Court of Criminal Appeals affirmed, holding the record was sufficiently developed, the court implicitly made the two required decisions, and incarceration was appropriate because less‑restrictive measures had recently failed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient proof McCaig violated probation	State: testimony and physical evidence (drugs, scales, cash, firearm, subsequent arrests) met preponderance standard	McCaig: did not contest existence of violations on appeal	Held: Violation proven by preponderance; revocation supported
Whether trial court erred by failing to expressly consider alternatives and place findings on the record before ordering incarceration	State: no requirement for a separate hearing; trial court need not repeat analysis once violation found if record supports consequence	McCaig: trial court failed to make explicit two‑step findings (revocation vs. consequence) and did not consider alternatives or his drug‑treatment argument	Held: Court found trial court implicitly conducted the two‑step analysis and placed sufficient findings for appellate review; de novo review affirmed full revocation and incarceration because less‑restrictive measures had recently failed

State v. Craig Dagnan, 641 S.W.3d 751 (Tenn. 2022) (clarifies two‑step revocation framework and appellate review standard)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (appellate review standard for trial court findings sufficiency)
State v. King, 432 S.W.3d 316 (Tenn. 2014) (importance of record findings to permit meaningful appellate review)
State v. Beard, 189 S.W.3d 730 (Tenn. 2005) (enumeration of post‑revocation sentencing options)
State v. Hunter, 1 S.W.3d 643 (Tenn. 1999) (same—available consequences after revocation)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (preponderance standard for probation violation proof)
State v. Shaffer, 45 S.W.3d 553 (Tenn. 2001) (trial judge discretion to revoke probation)