Appeals panel hears challenge to consecutive sentences under Wilkerson in Ragland case

A three-judge Tennessee appellate panel heard arguments on whether a trial court made adequate factual findings under Wilkerson to justify imposing consecutive sentences on defendant Tondre Ragland.

The panel, which included Judge Robert Wedemeyer, Judge John W. Campbell Sr. and Judge Matthew J. Wilson, heard defense counsel argue that the trial court’s post-remand findings were insufficient and that the appellate court should reverse and impose concurrent sentences totaling 16 years. The state, represented by Courtney Orr, told the court the trial court had made factual findings — including that there were two separate victims and that the defendant fired shots over an extended period in a residential area — and asked the panel to affirm the 20-year aggregate sentence.

Why it matters: The question is whether the Wilkerson line of authorities requires more detailed, specific factual findings before a trial court may impose consecutive sentences on the basis that a defendant is a "dangerous offender." The panel’s…