State of Tennessee v. Patrick Russell Chambers, E2016-01324-CCA-R3-CD

Patrick Russell Chambers pleaded guilty to possession of contraband inside a penal institution (Class C felony) and stipulated he violated community corrections for an earlier reckless homicide sentence (6 months confinement + remainder on community corrections).
Chambers was arrested when he brought Suboxone and Xanax into the jail on the day he was to begin serving his six-month confinement; he said he did so to avoid withdrawal from prescribed opioids.
Presentence report showed an extensive criminal history (assaults, federal drug conviction, multiple misdemeanors) and substance‑use history; Chambers sought treatment and expressed remorse at sentencing.
Trial court imposed a ten‑year Range III persistent offender sentence for the contraband conviction (within-range) and revoked community corrections, ordering service of the remainder of the reckless homicide sentence.
Chambers appealed, arguing the trial court abused its discretion by denying alternative sentencing; the State defended the confinement and revocation.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Chambers)	Held
Whether trial court abused discretion by denying alternative (non‑confinement) sentence for contraband conviction	Confinement was appropriate given protection of the public, prior failures on community supervision, and sentencing factors	Confinement is not the least severe measure; his criminality stems from untreated addiction and he should receive treatment/community‑based alternatives	Affirmed — trial court did not abuse discretion; defendant failed to prove suitability for alternative sentence
Whether trial court erred in revoking community corrections for reckless homicide	Revocation proper because defendant admitted violating conditions by bringing narcotics into jail	Revocation improper because conduct driven by withdrawal/addiction and treatment would be more appropriate	Affirmed — record supports revocation; plea/stipulation and evidence show violation by preponderance

State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (abuse‑of‑discretion review with presumption of reasonableness for within‑range sentences)
State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (standard for review of alternative sentencing decisions)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (sentencing factors a trial court must consider)
State v. Harkins, 811 S.W.2d 79 (Tenn. 1991) (revocation of community corrections reviewed for abuse of discretion)