State of Tennessee v. Lee Allen Denton

The Defendant, Lee Allen Denton, appeals from the order of the trial court revoking his
probation. He argues that (1) the trial court violated his due process rights by failing to
provide a neutral and detached hearing body and instead applying a blanket policy of total
revocation; (2) the trial court imposed an illegal sentence by increasing his release
eligibility percentage from sixty percent to one hundred percent through a judge-signed
mittimus; and (3) the trial court failed to properly apply the required two-step analysis for
probation revocation. After review, we affirm the trial court's finding that the Defendant
violated his probation and the revocation of probation; however, the trial court failed to
articulate sufficient findings regarding the consequences imposed, as required by State v.
Dagnan, 641 S.W.3d 751 (Tenn. 2022). Because the record is insufficiently developed for
meaningful de novo review, we remand for entry of findings on the record consistent with
Dagnan.