State of Tennessee v. Ioka Kimbuke Kyles, M2016-00796-CCA-R3-CD

Defendant Ioka Kimbuke Kyles pleaded guilty to three counts: two for facilitation of aggravated child abuse and one for facilitation of aggravated child neglect; all three convictions were to run concurrently in confinement, with an eight-year term for each count.
The indictment originally charged six counts of aggravated child abuse and one count of aggravated child neglect; the guilty pleas resolved some counts and other counts were dismissed.
The sentencing court, after considering the presentence report and evidence, imposed concurrent eight-year sentences in confinement for all three convictions.
The State presented extensive victim-witness and investigative evidence showing severe and ongoing abuse of a 7-year-old victim, including long-term confinement, beating, starvation, and abuse witnessed by others.
On appeal, Kyles challenged only the denial of alternative sentencing; the State urged the court to uphold the confinement sentence as reasonable under the sentencing framework.
The Court of Criminal Appeals affirmed, holding the trial court properly applied the statutory factors and there was no abuse of discretion in denying an alternative sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the denial of an alternative sentence an abuse of discretion?	State argues proper consideration of factors.	Kyles contends court failed to justify denial.	No abuse of discretion; sentence consistent with statutory purposes.
Is Kyles eligible for probation given the offenses and record?	Caudle framework supports denial for non-favorable offender.	Standard offender status could favor probation.	Not eligible for probation; three Class B felonies and serious offense.
Did the court properly apply statutory factors 40-35-103(1)(A)-(C)?	Court found history, seriousness, and deterrence warranted confinement.	Arguments about less restrictive means not clearly favored.	Court properly considered factors and declined alternative sentencing.

State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (abuse of discretion standard for within-range sentences; presumption of reasonableness)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (foundation for determining denial of probation; statutory factors)
State v. Fields, 40 S.W.3d 435 (Tenn. 2001) (probation eligibility and consideration of alternatives)