State of Tennessee v. Scottie R. Buckles, E2016-01645-CCA-R3-CD

Scottie R. Buckles pled guilty in ten separate Sullivan County cases to 63 offenses (primarily property crimes, identity theft, forgery, and misdemeanors) and received an effective 15-year sentence as a Range II multiple offender; sentences in three cases were ordered consecutive.
The 15-year sentence was ordered to run consecutively to a prior revoked-probation 10-year sentence, producing a 25-year effective term.
At the sentencing/hearing on alternative sentencing, the trial court acknowledged Buckles’ military service, education, cooperation with police, drug-abuse history, and outstanding restitution (~$13,177).
The trial court explicitly considered community corrections and the ‘‘special needs’’ (drug treatment) provision but denied any alternative sentence, citing Buckles’ extensive prior record described as "refrigerator size class."
Buckles appealed the denial of alternative sentencing, arguing the trial court failed adequately to consider his substance-abuse treatment needs and the special-needs provision of the Community Corrections Act.
The Court of Criminal Appeals reviewed for abuse of discretion and affirmed, finding the trial court considered relevant sentencing principles and Buckles’ drug history but permissibly concluded incarceration was warranted given his extensive criminal history.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Buckles)	Held
Whether trial court abused discretion by denying alternative sentencing/community corrections	Trial court did not abuse discretion; it considered sentencing principles and defendant’s drug history and permissibly denied alternatives given extensive prior record	Trial court failed to adequately consider Buckles’ drug/substance-abuse history, availability of community treatment, and special-needs community-corrections eligibility	Affirmed: no abuse of discretion — court considered special-needs factors and reasonably denied alternative sentence

State v. Caudle, 388 S.W.3d 273 (Tenn. 2012) (standard of review for alternative sentencing is abuse of discretion with presumption of reasonableness for within-range sentences)
State v. Bise, 380 S.W.3d 682 (Tenn. 2012) (record must show sentence complies with statutory purposes and principles)
State v. Carter, 254 S.W.3d 335 (Tenn. 2008) (appellant bears burden to show sentence impropriety; review limited even if appellate court would reach different result)
State v. Ashby, 823 S.W.2d 166 (Tenn. 1991) (defendant bears burden under sentencing statutes and comments on appellate review scope)
State v. Boston, 938 S.W.2d 435 (Tenn. Crim. App. 1996) (elements required to place offender in community corrections under the special-needs provision)