State of Tennessee v. Jonathan David Patterson

We granted this appeal to determine what showing, if any, a defendant must make to prevail on a motion for reduction of sentence under Rule 35 of the Tennessee Rules of Criminal Procedure, where the defendant pleaded guilty without an agreement as to sentencing, pursuant to Tennessee Rule of Criminal Procedure 11(c)(1)(B). The Court of Criminal Appeals held that a defendant must present post-sentencing information or developments warranting a reduction of sentence to prevail on a Rule 35 motion. We disagree and limit this standard to Rule 35 motions seeking reduction of specific sentences imposed in exchange for guilty pleas, pursuant to Tennessee Rule of Criminal Procedure 11(c)(1)(C). Accordingly, we reverse the judgment of the Court of Criminal Appeals and reinstate the trial court’s judgment granting the defendant’s Rule 35 motion and reducing his aggregate sentence.