TBA Law Blog


Posted by: Barry Kolar on Dec 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 opinion came in a case that 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.