State of Tennessee v. Kelly Lynn Chandler, M2016-00053-CCA-R3-CD

Defendant Kelly Lynn Chandler pled guilty to theft under $500 on April 17, 2014, receiving an eleven-month, twenty-nine-day suspended sentence on supervised probation.
Probation conditions required obedience to laws, monthly reporting, immediate notice of arrests/traffic violations, and not abusing intoxicants or engaging in assaultive behavior.
While on probation, Chandler was arrested for DUI (Jan. 11, 2015), implicated in vandalism/public intoxication/domestic assault arising March 15, 2015 (arrested June 4, 2015), and cited for driving on a revoked license (traffic stop July 23, 2015); an amended probation-violation warrant alleged these and additional reporting failures.
At the December 10, 2015 revocation hearing the State presented testimony and a certified driving record; Chandler offered no contrary evidence and requested treatment instead of incarceration.
The trial court found probation violations (DUI, misdemeanor vandalism, driving on revoked license), revoked probation, and ordered Chandler to serve the original sentence at 75% in county jail, with possible consideration of furlough to residential treatment if she filed proper motions.
The Court of Criminal Appeals affirmed, concluding the trial court did not abuse its discretion and that time on probation does not count toward the sentence unless the probation term is successfully completed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in revoking probation and ordering original confinement	Court had substantial evidence of multiple probation violations and acted within discretion to reinstate original sentence	Revocation was excessive; requested rehabilitation rather than incarceration	Affirmed: no abuse of discretion; substantial evidence supported revocation and imposition of original sentence
Whether defendant was entitled to credit for time served on probation (only ~95 days remained)	Time on probation does not constitute completion; tolling occurred when first warrant filed	Defendant argued remaining probation period made revocation disproportionate and sought credit	Affirmed: probation time counts only if entire term completed; tolling and pending violations precluded credit

State v. Lewis, 917 S.W.2d 251 (Tenn. Crim. App. 1995) (violation during probationary period permits reinstatement of original sentence)
State v. Shaffer, 45 S.W.3d 553 (Tenn. 2001) (revocation review requires showing of abuse of discretion; court will not overturn if substantial evidence supports finding)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (no abuse of discretion if substantial evidence of probation violation exists)
State v. Hunter, 1 S.W.3d 643 (Tenn. 1999) (time served on probation does not count toward sentence unless defendant successfully completes entire probationary term)