TBA Law Blog

TBA Law Blog

Supreme Court: Appeal of Probation Revocation Not Moot Though Sentence Served

Posted by: Azya Thornton on Jul 18, 2025

The Tennessee Supreme Court ruled in State v. Shanessa L. Sokolosky that an appeal of a probation revocation is not moot even if the defendant completed the sentence. Sokolosky, who pleaded guilty in 2019 and received probation instead of jail time, was later alleged to have violated probation and ordered to serve the rest of her sentence in custody. She challenged the arrest warrant, arguing unethical practices by the probation company. By the time the appeal reached the Court of Criminal Appeals, Sokolosky's sentence had ended, and she had been released from all custody or supervision. The court dismissed the appeal as moot. According to a release, the Tennessee Supreme Court disagreed with the dismissal, saying the appeal was not moot because Sokolosky could still face consequences due to the probation violation. The court also clarified that its ruling was not an exception to the doctrine of mootness but one rendering the case not moot. It reversed the decision and sent the case back to the appeals court to be heard on the merits.

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