State Tennessee v. Corby Martin Blouvett

The Court of Criminal Appeals found that the trial court had misconstrued certain statutory sentencing provisions in establishing Corby Martin Blouvett II and Dennis James Ogle, defendants, as Range III career offenders and sentencing them as such. Specifically, the court held that the prior convictions used to enhance a defendants status beyond that of a standard offender must have been reduced to judgment before the commission of the offense which supports the enhancement. We granted the States application for review under Rule 11, Tenn. R. App. P. in order to construe and reconcile these provisions. To do so, we must decide the pivotal question--what is a "prior conviction"--as is referred to in the above-mentioned sentencing provisions. We agree with the Conclusion reached by the Court of Criminal Appeals; accordingly, we affirm its judgment.