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Wayne Morris Flood Probation Revocation Reversed

The Tennessee Court of Criminal Appeals reversed the Hickman County Circuit Court's probation revocation for defendant Wayne Morris Flood. The trial court had revoked his eight-year sentence for possession with intent to sell methamphetamine and ordered him to serve the remainder in confinement. The appellate court found the trial court abused its discretion and remanded for reinstatement to probation.

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.