State of Tennessee v. Justin Daniel Adams, M2015-00835-CCA-R3-CD

Defendant Justin Daniel Adams originally pleaded guilty to aggravated kidnapping but withdrew that plea; later pleaded guilty to aggravated assault (Class C) with an agreed out-of-range eight-year sentence and reserved manner-of-service to the trial court.
Offense facts: while giving the Defendant a ride, the victim alleges Adams produced two handguns, placed one at his ribs and one at his temple, and threatened him; the victim fled and reported the incident.
Defense presented family testimony describing Defendant as slow, nonviolent, with mental/learning disabilities and prior hospitalizations; Defendant claimed he did not point a gun and has a history of suicidal attempts and mental-health needs.
Trial court found the victim credible, found two guns were used (matching guns later found in Defendant’s mother’s vehicle), and found Defendant lacked candor and failed to accept responsibility.
Trial court denied alternative (probation) sentence and ordered the eight-year sentence to be served in confinement.
On appeal Defendant challenged the denial of an alternative sentence and sought correction of pretrial jail credit on the judgment form; the State agreed the judgment should be amended for pretrial credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of alternative sentence was an abuse of discretion	Trial court properly weighed offense severity, lack of candor, danger, and deterrence; confinement appropriate	Adams argued he was a favorable candidate for alternative sentencing (Class C, no prior record, mental-health issues, strong community support)	Affirmed: no abuse of discretion; trial court’s findings (egregious conduct, two firearms, lack of candor, risk/need for deterrence) justified confinement
Whether judgment should reflect pretrial jail credit	State agreed judgment omitted applicable credit and should be corrected	Adams argued he was entitled to credit from Jan 6, 2015 to Mar 31, 2016	Remanded: judgment must be amended to show pretrial jail credit

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse-of-discretion standard with presumption of reasonableness for sentencing)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (applies Bise standard to alternative sentencing)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (sentencing factors to be considered)
State v. Dowdy, 894 S.W.2d 301 (Tenn. Crim. App. 1994) (candor relevant to rehabilitation and probation suitability)
State v. Kendrick, 10 S.W.3d 650 (Tenn. Crim. App. 1999) (lack of candor weighs against probation)
State v. Zeolia, 928 S.W.2d 457 (Tenn. Crim. App. 1996) (factors that may constitute evidence to the contrary for alternative sentencing)