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…