STATE OF TENNESSEE v. THOMAS KOONTZ - Articles

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STATE OF TENNESSEE v. THOMAS KOONTZ

Posted by: Azya Thornton on Jun 17, 2026

Court: TN Court of Criminal Appeals

Attorneys 1: Todd Estep, District Public Defender; and Colby A. Collins, Assistant District Public Defender, for the appellant, Thomas Koontz.

Attorneys 2: Jonathan Skrmetti, Attorney General and Reporter; Benjamin A. Ball, Senior Assistant Attorney General; Dan E. Armstrong, District Attorney General; and Dustin Click, Assistant District Attorney General, for the appellee, State of Tennessee.

Judge(s): AYERS

Defendant, Thomas Koontz, appeals the judgment of the Criminal Court for Hamblen County revoking his probation and ordering execution of his original eight‑year, six‑month sentence. He argues that the trial court (1) imposed an illegal sentence by altering his release eligibility from thirty percent to one hundred percent, and (2) failed to make the requisite findings on the record to justify ordering him to serve the entire sentence in confinement. Following our review of the record, the arguments and briefs of the parties, and the applicable law, we affirm the trial court’s finding that Defendant violated his probation and the revocation of probation; however, the trial court failed to articulate sufficient findings regarding the consequences imposed, as required by State v. Dagnan, 641 S.W.3d 751 (Tenn. 2022). Because the record is insufficiently developed for meaningful de novo review, we remand for entry of findings on the record consistent with Dagnan.

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