State of Tennessee v. Misty Ann Miller, M2016-01165-CCA-R3-CD

Misty Ann Miller pled guilty to three counts of attempted aggravated child neglect (Class B felonies) pursuant to a plea agreement providing concurrent 18-year sentences with 35% release eligibility; other indictment counts were dismissed.
She filed a pro se Tenn. R. Crim. P. 35 motion seeking sentence reduction based on mental and physical health problems and remorse; she also alleged ineffective assistance of counsel but was directed to post-conviction procedures for those claims.
The trial court appointed counsel and held an evidentiary hearing where Miller testified about longstanding bipolar disorder, PTSD, fibromyalgia, prior sexual abuse, and sobriety while incarcerated; she admitted these conditions were known and considered during plea negotiations.
The trial court denied the Rule 35 motion, reasoning the health issues were known at sentencing, the plea gave her a favorable disposition compared to the exposure she faced, and modifying the sentence would not serve the interests of justice given the child-related offense and her criminal history.
Miller appealed, arguing the lack of adequate medical care in TDOC constituted a post-sentencing development warranting reduction and that the trial court relied on underlying facts rather than the merits; the Court of Criminal Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller showed unforeseen post-sentencing developments warranting Rule 35 relief	Miller: inadequate medical/mental health treatment in TDOC is a post-sentencing development justifying reduction	State: health issues were known at plea/sentencing, so not unforeseen; no basis for modification	Held: Denied — health issues were known at plea; no new post-sentencing developments shown
Whether the trial court applied incorrect legal standard or ignored evidence	Miller: trial court relied on underlying facts, failed to address proof/arguments for Rule 35 relief	State: trial court reviewed plea, testimony, and considered those matters	Held: Denied — court addressed record and applied correct standard; no abuse of discretion

Hicks v. State, 945 S.W.2d 706 (Tenn. 1997) (plea-related sentencing principles and agreements)
Ruiz v. State, 204 S.W.3d 772 (Tenn. 2006) (abuse-of-discretion standard for Rule 35 review)
McDonald v. State, 893 S.W.2d 945 (Tenn. Crim. App. 1994) (Rule 35 allows modification only for interests of justice based on unforeseen post-sentencing developments)
Hodges v. State, 815 S.W.2d 151 (Tenn. 1991) (limitations on post-plea sentence modification)
Howell v. State, 185 S.W.3d 319 (Tenn. 2006) (defining abuse of discretion in sentencing contexts)