State of Tennessee v. Servadio M. Boyd

Defendant, Servadio M. Boyd, was convicted on a plea of guilty of possession of .5 grams or more of cocaine with intent to sell before the Davidson County Criminal Court in 2014. As part of his plea agreement with the State, Defendant agreed to an eight-year sentence with the manner of service to be decided by the trial court at a sentencing hearing. Prior to his sentencing hearing, however, Defendant left the jurisdiction. He was then arrested and convicted of dealing in cocaine and conspiracy to commit dealing in cocaine in the Vanderburgh Circuit Court of Indiana, for which he received a sentence of thirteen years’ incarceration. Based upon his failure to appear at his sentencing hearing in Davidson County, the trial court issued an arrest warrant and lodged a detainer against Defendant. In 2019, Defendant filed, in the Davidson County Criminal Court, a motion to dismiss the detainer, arguing that the charges against him should be dismissed with prejudice based on an alleged violation of the Interstate Agreement on Detainers. Following a hearing and briefing by the parties, the trial court granted Defendant’s motion and dismissed the case against Defendant. The State appealed. Following a thorough review, we reverse the judgment of the trial court and remand for further proceedings.