State of Tennessee v. Leon Noel

The Defendant, Leon Noel, pled guilty to several offenses over a period of years, and the trial court suspended each of his sentences to probation. In 2024, the State alleged that he violated a special condition requiring inpatient drug treatment. Following a revocation hearing, the trial court found a violation on that basis and ordered him to serve the balance of each of his sentences in confinement. On appeal, the Defendant contends that his conduct amounted only to a technical violation and that the trial court erred in revoking all of his suspended sentence. Upon our review, we conclude that the record does not establish whether the treatment condition applied to the suspended sentences in four of the cases, and we remand those cases for additional findings. As to the remaining case, which includes suspended felony and misdemeanor sentences, we hold that the violation constituted a first instance of a technical violation. The trial court, therefore, lacked authority to revoke the suspended felony sentence, but the revocation of the suspended misdemeanor sentence was within its discretion. We accordingly affirm in part, reverse in part, and remand for further proceedings.