State v. Ryan Little

Citation: Not availableDocket: W1999-01033-CCA-R3-CD

Court: Court of Criminal Appeals of Tennessee; August 30, 2000; Tennessee; State Appellate Court

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Ryan J. Little was convicted of aggravated robbery, aggravated burglary, and three counts of attempted aggravated robbery, resulting in a total effective sentence of twenty-four years due to the trial court's determination of him as a "dangerous offender." The appellant appealed the imposition of consecutive sentences. The trial court sentenced him to twelve years for aggravated robbery, six years for aggravated burglary, and six years for each count of attempted aggravated robbery. The events leading to the convictions occurred on July 19, 1998, when Little and two accomplices surrounded college students Ben Reed and Krystina Elton at her parents' residence, demanding money and ultimately forcing their way into the home. During the encounter, Reed was assaulted, and a struggle ensued, leading to multiple gunshots being fired. The appellate court affirmed the sentencing decision of the trial court, supporting the classification of Little as a dangerous offender. The ruling was delivered by Judge David G. Hayes, with Judges JAMES CURWOOD WITT, JR. and JOHN EVERETT WILLIAMS concurring.

Reed returned to Glenn's bedroom to find the appellant had freed himself and attempted to strike Reed. Reed and Glenn subdued the appellant until police arrived. The court reviews sentencing with a presumption that the trial court's decisions are correct, placing the burden on the appellant to prove any impropriety in the sentence (Tenn. Code Ann. 40-35-401(d)). The trial court categorized the appellant as a dangerous offender under Tenn. Code Ann. 40-35-115(b)(4) and documented its findings, emphasizing the serious threat posed by the appellant, who, along with accomplices, committed armed robbery and attempted to harm victims. The court imposed consecutive sentences, finding that the appellant's actions warranted such a decision to ensure public safety. Specifically, the aggravated robbery sentence of twelve years was made consecutive to the burglary sentence, with additional counts of criminal-attempt aggravated robbery also running consecutively. The appellant contended that consecutive sentences were unjustified, arguing that the same facts used to classify him as a dangerous offender were also used to establish the offenses. For consecutive sentences to be valid, the court must determine the presence of statutory criteria and ensure the aggregate sentence is proportional to the offenses while protecting the public (Gray v. State, 538 S.W.2d 391, 393; State v. Wilkerson, 905 S.W.2d 933, 937). Despite meeting these criteria, the trial court has discretion in imposing consecutive sentences, and appellate courts afford significant weight to the trial court's discretion if the sentencing principles are correctly applied. The fairness of the sentence is the primary concern in evaluating the trial court's discretion.

Consecutive sentences are imposed on dangerous offenders to safeguard society from individuals committing aggravated crimes that threaten human life. According to the ruling in Gray, a defendant is deemed a 'dangerous offender' based solely on the circumstances of the crimes leading to sentencing. A defendant may be classified as such if their convictions demonstrate a disregard for human life and a willingness to engage in high-risk criminal behavior. The court found that the appellant's actions in this case exemplified this definition, with sufficient evidence supporting the trial court’s classification of him as a dangerous offender under Tenn. Code Ann. 40-35-115(b)(4). Despite the appellant being only nineteen years old, his extensive prior criminal history necessitated confinement to protect the public from future offenses. Given the five counts involved, consecutive sentences were deemed appropriate relative to the severity of the crimes. The appellant did not demonstrate that the trial court abused its discretion in imposing consecutive sentences, leading to the affirmation of the judgment. The presentence report indicated the appellant's history includes juvenile offenses such as evading arrest, theft, criminal trespass, vehicle theft, possession of a weapon, aggravated burglary, disorderly conduct, and loitering.