State of Tennessee v. Nathan Craig
M2020-01124-CCA-R3-CD
| Tenn. Crim. App. | Jul 7, 2021Background
- Nathan Craig pleaded guilty to robbery on Oct. 3, 2017; received a four‑year sentence suspended to ten years of supervised probation.
- Probation history included an April 2018 Instagram photo showing a pistol (partial revocation and reinstatement) and positive marijuana screens in 2019 (no warrant sought).
- Craig received a mitigated criminal littering citation in Marshall County (June 27, 2019), failed to appear for the August 20, 2019 court date, and a failure‑to‑appear warrant issued.
- After a November 15, 2019 traffic stop revealed outstanding warrants, Craig was arrested; he later resolved the Marshall County matter and reported to probation on March 9, 2020.
- A March 24, 2020 probation‑violation report alleged Craig failed to report the Marshall County citation and failure to appear; at the revocation hearing the trial court found he had violated probation and fully revoked it, ordering him to serve the remainder of the four‑year sentence in confinement.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Craig) | Held |
|---|---|---|---|
| Whether the trial court abused its discretion in revoking probation | The State: proof by a preponderance showed violations (failure to report; failure to appear); revocation proper | Craig: court improperly credited State over his testimony; abuse of discretion | Court affirmed: no abuse of discretion; credibility findings supported revocation |
| Whether prior conduct (pre‑dating an earlier revocation) can support a later revocation | The State: probation may be revoked based on previously committed crimes once known to the court | Craig: the conduct occurred before the earlier revocation and charges were dismissed, so it should not justify revocation | Court held prior crimes, once known, can justify revocation even if committed earlier or charges dismissed |
| Whether the record supported finding Craig failed to report the Marshall County contact | The State: probation records and SOPs show no reporting; officer testimony credible | Craig: he told other probation personnel and manager about the matter; file lacks forms because he reported | Court found officer testimony and records credible; failure‑to‑report finding supported |
Key Cases Cited
- State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse‑of‑discretion standard and presumption of reasonableness for sentencing/revocation)
- State v. Hunter, 1 S.W.3d 643 (Tenn. 1999) (trial court options upon probation revocation and discretion to order original sentence)
- State v. Phelps, 329 S.W.3d 436 (Tenn. 2010) (definition of abuse of discretion)
- Bledsoe v. State, 387 S.W.2d 811 (Tenn. 1965) (credibility determinations at revocation hearings are for the trial court)
- Carver v. State, 570 S.W.2d 872 (Tenn. Crim. App.) (trial court findings carry the weight of a jury verdict)
- State v. Delp, 614 S.W.2d 395 (Tenn. Crim. App.) (revocation may be based on new criminal conduct regardless of acquittal)
- State v. Stubblefield, 953 S.W.2d 223 (Tenn. Crim. App. 1997) (revocation may be based on acts committed prior to probation if unknown when probation was granted)