State of Tennessee v. Michael Stephen Baucom, Jr.

The Defendant, Michael Stephen Baucom, Jr., pleaded guilty to multiple counts stemming from a series of burglaries under four different indictments. After a sentencing hearing, the trial court sentenced the Defendant as a Range II offender for his conviction of possession of a firearm by a convicted felon based on his two prior felony convictions, one of which was a 2015 conviction for theft of property valued over $1,000, a Class D felony at the time. On appeal, the Defendant contends the trial court erred when it sentenced him as a Range II offender because, in 2022 when he was sentenced, the theft for which he had been convicted was reclassified to a Class E felony, which would not be an appropriate basis upon which to classify him as a Range II offender. After review, we affirm the trial court’s judgments.