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Wayne Morris Flood Probation Violation Appeal, Judge Sword Dissent

The Tennessee Court of Criminal Appeals issued a divided ruling in State v. Wayne Morris Flood, No. M2025-01299-CCA-R3-CD, addressing the trial court's failure to make sufficient on-the-record findings when revoking the defendant's probation. The majority held that because the trial court did not specify whether the defendant committed a technical violation versus absconding, full revocation was contrary to Tennessee law and the case must be reversed. Judge Sword's dissent argued that de novo review of the record supports a finding of absconding and that the trial court did not abuse its discretion in fully revoking probation.

Priority review Enforcement Criminal Justice

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