Student comments on the Tennessee Supreme Court decision “State of Tennessee v. Kevin E. Trent”. The central holding vacating the sentence in this case did not establish a new doctrine of law but merely reiterated the holding in Travis that the essential elements of the offense alone cannot justify denial of probation in a probation-eligible offense. The Trent decision should be viewed by trial judges and practitioners primarily as a reminder of that principal. On the other hand, the court broke some new ground in appellate review. Prior decisions established that appellate courts can only uphold a sentence if the record is sufficient record to allow “meaningful appellate review.” Trent took that rule a step further by requiring a sufficient record for an appellate court to affirmatively impose a sentence.
Criminal Law, Tennessee, Tennessee Supreme Court, Sentencing, Appellate Review
Raybin, Ben and Lamar, Juliana
"State of Tennessee v. Kevin E. Trent,"
Belmont Criminal Law Journal: Vol. 1, Article 14.
Available at: https://repository.belmont.edu/clj/vol1/iss1/14