Court Extends Abuse of Discretion Standard to Sentencings

The Tennessee Supreme Court upheld the three-year sentence for Christine Caudle by applying the abuse of discretion standard of review recently adopted in State of Tennessee v. Susan Renee Bise. The Court of Criminal Appeals declined to conduct of review of Caudle’s sentences because she failed to include in the record a transcript of the hearing on the guilty plea. Upon further appeal, the Court ruled the trial court did not abuse its discretionary authority since it found the record was sufficient without the transcripts for meaningful review. Read the opinion.

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