State of Tennessee v. James Courtney Shane

This is a probation violation matter wherein Defendant, James Courtney Shane, appeals both the determination of a violation and the determination of a full revocation consequence. In April 2025, Defendant pled guilty to one count of abuse of an elderly or vulnerable adult and one count of aggravated assault. The trial court imposed an effective eight-year sentence and placed Defendant on supervised probation. Within two months Defendant was arrested on a new felony charge. The trial court subsequently revoked Defendant’s probation in full and ordered him to serve the remainder of his sentence in confinement. On appeal, Defendant argues (1) the probation violation warrant was invalid because the corresponding affidavit contained procedural errors, (2)the trial court erred by admitting a TBI lab report without making the proper hearsay findings of good cause and reliability, and (3) the trial court failed to make the appropriate findings in its consequence determination pursuant to State v. Dagnan, 641 S.W.3d 751 (Tenn. 2022). Defendant waived his first issue during oral argument. After review, we conclude the admission of the TBI lab report was error, but the error was harmless beyond a reasonable doubt. We also conclude the record is not sufficiently developed for this Court to conduct a meaningful review of the consequence determination. We, therefore, vacate the revocation orders and remand the case to the trial court for further findings.