Tennessee Supreme Court Clarifies the Standards for Trial Courts to Apply When Ruling on Motions to Reduce Sentences Imposed on Guilty Pleas

December 10, 2018

The Tennessee Supreme Court today held that a defendant who pleads guilty is not required to present proof of post-sentencing changed circumstances to prevail on a motion for reduction of sentence under Rule 35 of the Tennessee Rules of Criminal Procedure, if the guilty plea did not include an agreement as to a specific sentence.

The case before the Court began in 2015, when the defendant, Jonathan David Patterson, broke into several cars and a building in Putnam County, stealing two vehicles and also stealing property from the vehicles and the building.  Law enforcement apprehended Mr. Patterson with some of the stolen property in his possession and arrested him.  He cooperated with the authorities, and this enabled them to recover much of the stolen property and restore it to the victims.  Mr. Patterson was charged with 42 offenses and eventually pled guilty to 20 offenses without any agreement as to the sentences that would be imposed on the pleas.  A guilty plea that does not include an agreement is known as an “open plea” and requires the trial court to impose sentence. 

At Mr. Patterson’s sentencing hearing, the trial court received evidence of his previous felony convictions and parole violations and heard argument from the State that Mr. Patterson’s extensive criminal history warranted a lengthy sentence.  Mr. Patterson spoke at the hearing, apologized for his crimes, and explained that he had been struggling with drug addiction for many years when these crimes were committed.  Mr. Patterson’s sister also testified and corroborated his testimony.  Both Mr. Patterson and his sister asked for leniency in sentencing.  Mr. Patterson emphasized that he had not committed any violent crimes, had cooperated with law enforcement, and had pleaded guilty without an agreement as to sentencing.   The trial court agreed with the State’s argument and imposed an aggregate 31-year sentence.

Mr. Patterson then filed a Rule 35 motion asking the trial judge to reduce his sentence.  The trial court granted the Rule 35 motion and reduced Mr. Patterson’s aggregate sentence to 19 years.

When the State appealed, the Court of Criminal Appeals held that a defendant cannot prevail on a Rule 35 motion unless the defendant offers proof of post-sentencing changed circumstances justifying a reduction.  Because the defendant failed to satisfy this showing, the Court of Criminal Appeals reversed the trial court’s decision on the Rule 35 motion and reinstated the original 31-year sentence.

The Tennessee Supreme Court granted Mr. Patterson permission to appeal and held that Rule 35 provides only one limit on a trial court’s discretion to reduce a sentence—the reduction must be in the interests of justice.  The Supreme Court acknowledged that its own prior decisions had not been clear about the standards applicable to Rule 35 motions seeking reduction of sentences imposed on guilty pleas.  The Supreme Court clarified its prior decisions by holding that a defendant need only show post-sentencing changed circumstances if the Rule 35 motion requests reduction of a sentence imposed on a guilty plea that included an agreement as to the appropriate specific sentence. The Supreme Court explained that the showing is not required to prevail on a Rule 35 motion requesting reduction of a sentence imposed on an open guilty plea.  Because the defendant entered an open guilty plea, the Supreme Court concluded that the trial court did not abuse its discretion in granting his Rule 35 motion without any proof of post-sentencing changed circumstances.  The Supreme Court reversed the Court of Criminal Appeals’ decision and reinstated the trial court’s decision reducing the defendant’s sentence from 31 to 19 years.

To read the unanimous opinion in State of Tennessee v. Jonathan David Patterson, authored by Justice Cornelia A. Clark, go to the opinions section of tncourts.gov.