State of Tennessee v. Christopher Caldwell

On April 21, 2016, the Defendant, Christopher Caldwell, was convicted of three felony offenses in Davidson County and sentenced to fifteen years in Community Corrections. On October 20, 2016, he was convicted in Sumner County of two felony offenses and sentenced to twelve years in Community Corrections, consecutive to the Davidson County sentences. The Defendant violated the terms of his Davidson County sentence and was ordered to serve one year and then return to Community Corrections. More than eight months later, after learning that the Defendant had also violated the terms of his Sumner County sentence and had been ordered to serve that sentence in the Tennessee Department of Correction, the Davidson County trial court ordered the Defendant to serve his Davidson County sentences in the Tennessee Department of Correction. Because the Davidson County trial court’s original disposition of the Community Corrections violation was final, and no additional warrant alleging a new violation of Community Corrections had been filed, the Davidson County trial court lacked jurisdiction to order the service of the Davidson County sentences in the Tennessee Department of Correction. The State concedes this point. Accordingly, we reverse and vacate the Davidson County trial court’s June 21, 2019 order requiring service of the Defendant’s Davidson County sentences in the Tennessee Department of Correction.