Tennessee Code Annotated

Tenn. Code Ann. § 40-35-104 (2026)

Sentencing alternatives

✓ current as of May 2026
Find cases: SyfertCases citing this section JustiaTenn. Code CornellLII Search CasesGoogle Scholar

Amended by 2021 Tenn. Acts, ch. 409, s 10, eff. 7/1/2021.

Amended by 2021 Tenn. Acts, ch. 409, s 9, eff. 7/1/2021.

Amended by 2016 Tenn. Acts, ch. 906, s 6, eff. 1/1/2017.

Acts 1989, ch. 591, § 6; 1990, ch. 1030, § 36; 1991, ch. 374, §§ 1, 2; 1992, ch. 878, § 2; 1996, ch. 699, § 2.


Notes of Decisions
Cited in 234 cases (15 in the last 5 years), 1986–2025 · leading case: State v. Davis, 940 S.W.2d 558 (Tenn. 1997).
State v. Davis, 940 S.W.2d 558 (Tenn. 1997). · cites it 10× “We recognize that, effective July 1, 1996, Tenn. Code Ann. § 40-35-104 (c)(2) was amended to include the following sentencing alternative: "Payment of restitution to the victim or victims either alone or in addition to any other sentence authorized by this subsection.”
State v. Moss, 727 S.W.2d 229 (Tenn. 1986). · cites it 6× “T.C.A. § 40-35-104 enumerates a series of combinations of confinement, fines, and rehabilitative probation; these vary from a fine to continuous confinement in the penitentiary.”
State v. Bottoms, 87 S.W.3d 95 (Tenn. Crim. App. 2001). · cites it 6× “” Effective July 1, 1996, restitution is available where a defendant has been sentenced pursuant to Section 40-35-104(c)(2) (authorizing restitution in addition to a sentence of continuous confinement in the jail or workhouse).”
State v. Fletcher, 805 S.W.2d 785 (Tenn. Crim. App. 1991). · cites it 4× “See T.C.A. § 40-35-104(b). The rebuttable presumption at issue in this case, though, does not appear to restrict the trial court’s discretion to the extent the defendant claims in her appeal.”
State v. Palmer, 902 S.W.2d 391 (Tenn. 1995). · cites it 7× “Tenn.Code Ann. §§ 40-35-104, -117 & -302 (1990 Supp.”
State v. Hartley, 818 S.W.2d 370 (Tenn. Crim. App. 1991). · cites it 4× “These sentencing alternatives to confinement are specifically provided by the legislature in T.C.A. § 40-35-104(c) to meet the goals of the 1989 Act and their application is controlled by the Act.”
State of Tennessee v. Kevin E. Trent, 533 S.W.3d 282 (Tenn. 2017). · cites it 2× “See Tenn. Code Ann. § 40-35-104 (c) (2010). The availability of an alternative sentence depends upon the conviction offenses and the defendant’s prior convictions, if any.”
Shorts v. Bartholomew, 278 S.W.3d 268 (Tenn. 2009). · cites it 5× “7 See Tenn.Code Ann. §§ 40-35-104, Sentencing Comm’n Cmts; 40-35-212, Sentencing Comm’n Cmts; 40-35-314(a).”
State v. Anderson, 857 S.W.2d 571 (Tenn. Crim. App. 1992). · cites it 4× “Also, the sentencing alternatives provided by the legislature in T.C.A. § 40-35-104 do not include judicial diversion.”
State v. Williams, 52 S.W.3d 109 (Tenn. Crim. App. 2001). · cites it 5× “The first reason why we cannot accept the state’s argument is based on the alternative sentencing options enumerated in Code section 40-35-104. Full probation is listed as one option.”
Thomas v. Haslam, 303 F. Supp. 3d 585 (M.D. Tenn. 2018). · cites it 2× “Tenn. Code Ann. § 40-35-104 (c)(1). "[T]he defendant's ability to pay the fine is a factor in the establishment of the fine," but "it is not a controlling factor.”
State of Tennessee v. Susan Renee Bise, 380 S.W.3d 682 (Tenn. 2012). “If the appeal was by the State, the appellate court could affirm, vacate, set aside, or reduce the sentence or remand, but it could not “increase the specific length of the sentence by the trial court if the sentence was imposed within the proper range and if the defendant was…”
— Tenn. Code Ann. § 40-35-104(4) — 3 cases
State of Tennessee v. Jeannie Hudson (Tenn. Crim. App. 2002).
State v. Alexander Lee (Tenn. Crim. App. 2000).
— Tenn. Code Ann. § 40-35-104(6) — 1 case
State of Tennessee v. William E. Ross (Tenn. Crim. App. 2004).
— Tenn. Code Ann. § 40-35-104(a) — 6 cases
State v. Palmer, 902 S.W.2d 391 (Tenn. 1995). “Tenn.Code Ann. §§ 40-35-104, -117 & -302 (1990 Supp.”
State v. Martin, 146 S.W.3d 64 (Tenn. Crim. App. 2004).
State v. Lane, 56 S.W.3d 20 (Tenn. Crim. App. 2000).
State of Tennessee v. Carl R. Greene (Tenn. Crim. App. 2020).
State of Tennessee v. Michael Broyles (Tenn. Crim. App. 2021).
— Tenn. Code Ann. § 40-35-104(b) — 11 cases
State v. Fletcher, 805 S.W.2d 785 (Tenn. Crim. App. 1991). “See T.C.A. § 40-35-104(b). The rebuttable presumption at issue in this case, though, does not appear to restrict the trial court’s discretion to the extent the defendant claims in her appeal.”
Shorts v. Bartholomew, 278 S.W.3d 268 (Tenn. 2009). “7 See Tenn.Code Ann. §§ 40-35-104, Sentencing Comm’n Cmts; 40-35-212, Sentencing Comm’n Cmts; 40-35-314(a).”
Kevin D. McMillan v. State of Tennessee (Tenn. Crim. App. 2013).
— Tenn. Code Ann. § 40-35-104(b)(1) — 2 cases
State of Tennessee v. Randy G. McDaniel (Tenn. Crim. App. 2002).
— Tenn. Code Ann. § 40-35-104(c) — 26 cases
State v. Moss, 727 S.W.2d 229 (Tenn. 1986). “T.C.A. § 40-35-104 enumerates a series of combinations of confinement, fines, and rehabilitative probation; these vary from a fine to continuous confinement in the penitentiary.”
State v. Hartley, 818 S.W.2d 370 (Tenn. Crim. App. 1991). “These sentencing alternatives to confinement are specifically provided by the legislature in T.C.A. § 40-35-104(c) to meet the goals of the 1989 Act and their application is controlled by the Act.”
Shorts v. Bartholomew, 278 S.W.3d 268 (Tenn. 2009). “7 See Tenn.Code Ann. §§ 40-35-104, Sentencing Comm’n Cmts; 40-35-212, Sentencing Comm’n Cmts; 40-35-314(a).”
State of Tennessee v. Nicholas Cole (Tenn. Crim. App. 2016).
— Tenn. Code Ann. § 40-35-104(c)(1) — 4 cases
State of Tennessee v. Nicholas Cole (Tenn. Crim. App. 2016).
State of Tennessee v. Andrew Young Kim (Tenn. Crim. App. 2018).
State of Tennessee v. Dana Ray Davison (Tenn. Crim. App. 2019).
— Tenn. Code Ann. § 40-35-104(c)(2) — 27 cases
State v. Bottoms, 87 S.W.3d 95 (Tenn. Crim. App. 2001). “” Effective July 1, 1996, restitution is available where a defendant has been sentenced pursuant to Section 40-35-104(c)(2) (authorizing restitution in addition to a sentence of continuous confinement in the jail or workhouse).”
State v. Davis, 940 S.W.2d 558 (Tenn. 1997). “We recognize that, effective July 1, 1996, Tenn. Code Ann. § 40-35-104 (c)(2) was amended to include the following sentencing alternative: "Payment of restitution to the victim or victims either alone or in addition to any other sentence authorized by this subsection.”
State v. Alford, 970 S.W.2d 944 (Tenn. 1998).
State of Tennessee v. Douglas Beauregard (Tenn. Crim. App. 2018).
— Tenn. Code Ann. § 40-35-104(c)(2)(1990) — 1 case
State v. Davis, 940 S.W.2d 558 (Tenn. 1997). “We recognize that, effective July 1, 1996, Tenn. Code Ann. § 40-35-104 (c)(2) was amended to include the following sentencing alternative: "Payment of restitution to the victim or victims either alone or in addition to any other sentence authorized by this subsection.”
— Tenn. Code Ann. § 40-35-104(c)(3) — 16 cases
State v. Williams, 52 S.W.3d 109 (Tenn. Crim. App. 2001). “The first reason why we cannot accept the state’s argument is based on the alternative sentencing options enumerated in Code section 40-35-104. Full probation is listed as one option.”
State of Tennessee v. Hollis Fisk, Jr. (Tenn. Crim. App. 2016).
State of Tennessee v. Gary Allen Taylor (Tenn. Crim. App. 2017).
State of Tennessee v. Christopher Allen (Tenn. Crim. App. 2017).
— Tenn. Code Ann. § 40-35-104(c)(4) — 1 case
State of Tennessee v. Nicholas Cole (Tenn. Crim. App. 2016).
— Tenn. Code Ann. § 40-35-104(c)(5) — 10 cases
State v. Williams, 52 S.W.3d 109 (Tenn. Crim. App. 2001). “The first reason why we cannot accept the state’s argument is based on the alternative sentencing options enumerated in Code section 40-35-104. Full probation is listed as one option.”
State v. Millsaps, 920 S.W.2d 267 (Tenn. Crim. App. 1995).
State of Tennessee v. Matthew I. Tart (Tenn. Crim. App. 2010).
— Tenn. Code Ann. § 40-35-104(c)(8) — 4 cases
State v. Fletcher, 805 S.W.2d 785 (Tenn. Crim. App. 1991). “See T.C.A. § 40-35-104(b). The rebuttable presumption at issue in this case, though, does not appear to restrict the trial court’s discretion to the extent the defendant claims in her appeal.”
State v. Hartley, 818 S.W.2d 370 (Tenn. Crim. App. 1991). “These sentencing alternatives to confinement are specifically provided by the legislature in T.C.A. § 40-35-104(c) to meet the goals of the 1989 Act and their application is controlled by the Act.”
State v. Nail, 963 S.W.2d 761 (Tenn. Crim. App. 1997).
— Tenn. Code Ann. § 40-35-104(c)(8)(B) — 1 case
State v. Elam, 7 S.W.3d 103 (Tenn. Crim. App. 1999).
— Tenn. Code Ann. § 40-35-104(c)(9) — 11 cases
State v. Anderson, 7 S.W.3d 100 (Tenn. Crim. App. 1999).
State of Tennessee v. Mark Oden Potts (Tenn. Crim. App. 2017).
State of Tennessee v. Rafael Moreno, Jr. (Tenn. Crim. App. 2017).
State of Tennessee v. Scottie R. Buckles (Tenn. Crim. App. 2017).
— Tenn. Code Ann. § 40-35-104(d) — 1 case
State of Tennessee v. Marty Ray Harris (Tenn. Crim. App. 2010).
— Tenn. Code Ann. § 40-35-104(e) — 1 case
State v. Davis, 940 S.W.2d 558 (Tenn. 1997). “We recognize that, effective July 1, 1996, Tenn. Code Ann. § 40-35-104 (c)(2) was amended to include the following sentencing alternative: "Payment of restitution to the victim or victims either alone or in addition to any other sentence authorized by this subsection.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.