Opinion

STATE OF TENNESSEE v. VIDAL CHAD BRYANT

Court
Court of Criminal Appeals of Tennessee
Filed
Mar 6, 2026
Status
Published
Author
Judge J. Ross Dyer
On the bench
Judge J. Ross Dyer
Cited by
0 cases
Authority
More cited than 39.1%

affirming the primary holding in State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), that defendants seeking suspension of sentences under Tennessee Code Annotated section 40-35-306(c

How later courts described this case

  • affirming the primary holding in State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), that defendants seeking suspension of sentences under Tennessee Code Annotated section 40-35-306(c

Written by the judges who cited it.

The opinion

03/06/2026

IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE

AT KNOXVILLE

Assigned on Briefs February 18, 2026

STATE OF TENNESSEE v. VIDAL CHAD BRYANT

Appeal from the Criminal Court for Knox County

No. 125982 Hector Sanchez, Judge

___________________________________

No. E2025-00493-CCA-R3-CD

___________________________________

The defendant, Vidal Chad Bryant, pled guilty to attempted possession with the intent to

sell butyrylfentanyl, a Class C felony; possession with the intent to sell less than half a

gram of methamphetamine, a Class C felony; and possession of a firearm after having been

previously convicted of a felony drug offense, a Class C felony, for an agreed-upon

effective sentence of six years in the Tennessee Department of Correction (“TDOC”). On

appeal, the defendant argues that the trial court abused its discretion in denying his motion

to suspend the remainder of his sentence to probation. Following our review of the record,

the parties’ briefs, and applicable law, we affirm the trial court’s denial of the defendant’s

motion.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Criminal Court Affirmed

J. ROSS DYER, J., delivered the opinion of the court, in which ROBERT W. WEDEMEYER,

P.J., and JILL BARTEE AYERS, J., joined.

Mary J. Newton, Knoxville, Tennessee, for the appellant, Vidal Chad Bryant.

Jonathan Skrmetti, Attorney General and Reporter; Caroline Weldon, Assistant Attorney

General; Charme P. Allen, District Attorney General; and Sean D. Bright, Assistant District

Attorney General, for the appellee, State of Tennessee.

OPINION

Facts and Procedural History

The defendant was charged in a seven-count indictment with various drug and

weapons related offenses. On January 26, 2024, the defendant pled guilty pursuant to a

plea agreement with the State to attempted possession with the intent to sell

butyrylfentanyl, possession with the intent to sell less than half a gram of

methamphetamine, and possession of a firearm after having been previously convicted of

a felony drug offense. In exchange, the defendant received an effective sentence of six

years in the Tennessee Department of Correction (“TDOC”). The trial court accepted the

plea and entered the judgments that same day.

On December 19, 2024, the defendant filed a pro se motion to suspend the remainder

of his sentence to probation, which was later amended by appointed counsel. In his motion,

the defendant first averred that the trial court had jurisdiction to suspend his sentence

because he had been in continuous custody in Knox County since his arrest on August 18,

2022, and had never been transferred to a TDOC facility. The defendant pointed out that

he was denied parole on October 1, 2024, and would not be eligible again until February

2026. The defendant then asserted that it was in his best interest and that of society for the

remainder of his sentence to be served on probation due to his medical condition and for

him not to “take up space and resources needed for other inmates[.]”

The trial court conducted a hearing on the defendant’s motion on March 7, 2025, at

which the defendant testified that he had been incarcerated since his arrest on August 18,

2022, and had always been housed in a detention facility in Knox County or the Knox

County Jail. He had never been transferred to a TDOC facility. The defendant appeared

before the parole board on October 1, 2024, and was not granted parole. He would not be

considered for parole again until February 2026. The defendant also explained that he had

participated in numerous programs during his incarceration and provided certificates

detailing those.

The defendant then discussed the medical concerns he was presently facing.

Sometime in 2024, he began experiencing a gastrointestinal issue and was diagnosed with

an H. pylori bacterial infection. He was given medication, and it worked; however, he

began experiencing symptoms again a few weeks after he stopped taking it. The medical

staff was presently running tests and trying various medications to help his condition, but

the defendant explained in grotesque detail the symptoms he was still experiencing. The

defendant desired to seek treatment outside of the detention facility. In addition, the

defendant’s mother, two cousins, and a close friend had passed away while he was

incarcerated, all of which was causing him stress. He explained that if the court granted

his motion or when he was ultimately paroled, his plan was to move to New York to help

his sister since his mom’s passing. He also planned to get a job and go back to school.

On cross-examination, the defendant acknowledged that he received the benefit of

a shorter sentence than what he faced by virtue of the plea agreement. He also

acknowledged that he knew he would serve a prison sentence under the terms of the plea.

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Melissa Federici, a physician assistant with the Knox County Detention Facility,

reviewed the defendant’s file and recounted that the defendant was treated for “some

stomach issues” that turned out to be an H. pylori bacterial infection. The defendant was

“treated for that and retested afterwards and it was eradicated.” When the defendant started

complaining of symptoms again, “he was retested and that test was negative as well.”

Further testing had been ordered to see if there was another type of bacterial infection, but

the results were not back. According to Ms. Federici, the defendant received treatment

anytime he complained of a medical issue. Ms. Federici explained that the defendant was

informed that lifestyle choices could be contributing to his issues and was “advised to avoid

spicy, acidic foods, fried foods, fatty stuff because that can cause a lot of abdominal issues

and stomach issues and commissary has a lot of those items [but] he continues to order

them.”

Lieutenant Samantha Hill, a disciplinary grievance officer at the Knox County

Detention Facility, was familiar with the defendant’s disciplinary history. According to

the records, the defendant had received thirteen infractions during his period of

incarceration. Among the infractions were reports of assaulting other inmates, refusing to

lockdown, unauthorized transporting of items, using or possessing intoxicants, using or

possessing dangerous contraband, and lying or deception.

After hearing the arguments of the parties, the trial court denied the defendant’s

motion to suspend the remainder of his sentence to probation. The trial court first

determined that it had jurisdiction to consider the motion under Tennessee Code Annotated

sections 40-35-212 and 40-35-303(e) because the defendant remained in local custody

although serving a TDOC sentence. The court then observed that the defendant was not

“new to the criminal justice system” and that by accepting the plea agreement, the

defendant received a “substantial material benefit with regard to the potential exposure he

faced on the charged offenses.” The court recounted that the defendant was diagnosed with

an H. pylori infection that caused “GI issues,” but the infection was cured with medication.

The defendant was advised of lifestyle changes that could diminish some of his ailments

but continued to order food from the commissary that would trigger his symptoms. Thus,

the defendant was “experiencing . . . the product of his choices.” The court noted that the

defendant had “done some constructive things while he has been confined” but had also

received thirteen disciplinary infractions. The court surmised that the defendant was

“unhappy that he didn’t make parole, and he is attempting to probate the remainder of his

sentence.” The court ultimately concluded that there were no new developments that

“warrant[ed] an alteration [to the defendant’s sentence] in the interest of justice,” and that

the defendant needed to “continue to work on the things that he needs to, to make himself

have a better shot at parole when he ultimately gets there.”

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The defendant filed this timely appeal.

Analysis

On appeal, the defendant argues the trial court erred in denying his motion to

suspend the remainder of his sentence because his “health developments warrant an

alteration in the interest of justice.” The State responds that the trial court properly denied

the defendant’s motion because the defendant’s “health development” was a “common

stomach infection that had already been ‘eradicated’ through medication” and that any on-

going issues could be attributed to defendant’s commissary purchases against medical

advice. We agree with the State that the trial court acted within its discretion in denying

the defendant’s motion.

As an initial matter, we observe that the trial court determined it had jurisdiction to

consider the defendant’s motion under Tennessee Code Annotated sections 40-35-212 and

40-35-303(e).

Tennessee Code Annotated section 40-35-212 provides in pertinent:

(c) Unless the defendant receives a sentence in the department, the court shall

retain full jurisdiction over the manner of the defendant’s sentence service.

(d)(1) Notwithstanding subsection (c), the court shall retain full jurisdiction

over a defendant sentenced to the department during the time the defendant

is being housed in a local jail or workhouse awaiting transfer to the

department. The jurisdiction shall continue until the defendant is actually

transferred to the physical custody of the department.

In addition, section 40-35-303(e) provides:

(e) Probation shall be granted, if at all, at the time of the sentencing hearing

except for sentences served in a local jail or workhouse, or except during the

time a defendant sentenced to the department of correction is being housed

in a local jail or workhouse awaiting transfer to the department as provided

in § 40-35-212(d).

The State does not outright contest the trial court’s assessment of having jurisdiction

but points out that if the defendant was housed in the local jail due to a contract with the

TDOC, then the trial court would not retain jurisdiction. See State v. Nielsen, No. E2024-

00579-CCA-R3-CD, 2025 WL 212825, at *3 (Tenn. Crim. App. Jan. 16, 2025) (observing

that “[l]ocal jails may contract to house TDOC inmates to alleviate overcrowding in TDOC

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facilities, see T.C.A. § 4-3-603(b), and where a defendant is sentenced to the TDOC but is

housed in a local jail that has so contracted, the trial court is without jurisdiction to modify

the defendant’s sentence”), no perm. app. filed. However, as acknowledged by the State,

there is no evidence in the record indicating that such a contract was in place, and

presumably, the trial court would be in the best position to know whether there was such a

contract. The fact the defendant was convicted in Knox County, sentenced in Knox

County, and has always been housed in Knox County, at least up until the time he filed this

motion, suggests the defendant was “being housed in a local jail or workhouse awaiting

transfer to the department.” See State v. Lloyd, No. M2017-01919-CCA-R3-CD, 2018 WL

5077694, at *3 (Tenn. Crim. App. Oct. 17, 2018) (distinguishing jurisdictional

determination from that in State v. McGill, No. E2013-02069-CCA-R3-CD, 2014 WL

2854174, at *2 (Tenn. Crim. App. June 20, 2014), where the defendant had been transferred

from a county facility in one county to a city facility located in another county that had

contracted with the TDOC).

In any event, jurisdictional question aside, the trial court clearly acted within its

discretion in denying the defendant’s motion for suspension of the remainder of his

sentence to probation.

“This court has previously concluded that when a defendant pled guilty pursuant to

a plea agreement including an agreed-upon sentence, a motion to suspend a TDOC

sentence pursuant to Tennessee Code Annotated section 40-35-303(e) will only be granted

upon a showing that ‘post-sentencing information or developments have arisen that warrant

an alteration in the interest of justice.’” State v. Green, No. E2018-01287-CCA-R3-Cd,

2020 WL 1921088, at *5 (Tenn. Crim. App. Apr. 21, 2020) (quoting Lloyd, 2018 WL

5077694, at *8 (internal quotation omitted)), perm. app. denied (Tenn. July 17, 2020); see

State v. Patterson, 564 S.W.3d 423, 434 n.22 (Tenn. 2018) (affirming the primary holding

in State v. Ruiz, 204 S.W.3d 772, 778 (Tenn. 2006), that defendants seeking suspension of

sentences under Tennessee Code Annotated section 40-35-306(c) must establish that “post-

sentencing information or developments have arisen that warrant an alteration in the

interest of justice,” and noting that this Court had adopted the same standard for defendants

seeking suspension of sentences under Tennessee Code Annotated section 40-35-303(e)).

On appeal, we review the trial court’s denial of a defendant’s motion for suspension of

sentence for abuse of discretion. Lloyd, 2018 WL 5077694, at *9.

In this case, the defendant’s stated post-sentence circumstances that warrant a

suspension of sentence are his “health developments” and desire to assist his family. While

the defendant testified in detail about his gastrointestinal issues, the court also heard from

Ms. Federici who verified the defendant’s original diagnosis but explained that the

defendant had been cured of that condition through medication and that any lingering

gastrointestinal distress could be attributed to his dietary choices. Regardless, Ms. Federici

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affirmed that if dietary changes did not help the defendant’s “stomach complaints,” he

would continue to receive all the medical care he needed to address the issue. The

defendant insists that his “struggle with H. pylori and gastrointestinal issues would be

better treated if he were out of custody,” but fails to demonstrate how his treatment in

custody is inadequate. To the contrary, the record shows that the defendant’s complaints

have been taken seriously and that the medical team in the detention facility has continually

worked to diagnosis his problem. Additionally, the defendant’s inability to be present to

help his family after the loss of his mother is an unfortunate consequence of his criminal

actions but not necessarily an unexpected or unforeseen challenge. We conclude the trial

court acted within its discretion in denying the defendant’s motion, and the defendant is

not entitled to relief.

Conclusion

Based on the foregoing authorities and reasoning, we affirm the judgments of the

trial court.

S/ J. ROSS DYER _

J. ROSS DYER, JUDGE

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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