State of Tennessee v. Marquis Devann Churchwell, M2016-02218-CCA-R3-CD

Defendant Marquis Devann Churchwell pled guilty to one count of robbery and two counts of assault (against two jail officers); two aggravated kidnapping counts were dismissed. Sentencing was deferred to a later hearing.
Underlying robbery: victim was abducted, beaten, stripped, forced into the bed of a truck, and left naked on the street; Defendant held a knife to the victim’s throat and participated in the assault and robbery.
While jailed on the robbery charge, Defendant assaulted Officer Wright by pulling her hair and dumping a bottle containing urine and feces on her; Defendant later pled to the second officer-assault charge as well.
Defendant has longstanding serious mental-health diagnoses (schizophrenia, bipolar disorder, PTSD), reported not receiving meds consistently in jail, and a history of homelessness and substance use; he had prior felony convictions and multiple probation/Community Corrections revocations.
Trial court imposed an eight-year sentence for robbery and concurrent 11 months, 29 days for each assault, with the assault sentences consecutive to the robbery for a total effective sentence of 8 years, 11 months, 29 days, finding confinement appropriate due to prior failures of alternatives, public safety, and seriousness of the offenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by imposing confinement rather than an alternative sentence	State: confinement justified by defendant’s criminal history, failed prior alternatives, seriousness of offenses, and need to protect public	Churchwell: confinement is inappropriate given serious mental illness and prison won’t provide adequate treatment; alternative/community treatment would better address needs	Court affirmed: no abuse of discretion; within-range sentence and record support confinement given prior failures of alternatives, risk to public, and offense severity

State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (standard of review for sentencing with presumption of reasonableness for within-range sentences)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (upholding trial court sentencing findings where within-range and complying with sentencing principles)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (appellate deference to trial court sentencing choices)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (burden on appellant to demonstrate sentencing impropriety)
State v. Boston, 938 S.W.2d 435 (Tenn. Crim. App. 1996) (defendant must show community treatment would better serve than incarceration)
State v. Housewright, 982 S.W.2d 354 (Tenn. Crim. App. 1997) (probation must subserve ends of justice and best interests of public and defendant)
State v. Davidson, 509 S.W.3d 156 (Tenn. 2016) (requirement to enter a separate uniform judgment document for each count)