State of Tennessee v. Plaise Edward Spangler

The defendant, Plaise Edward Spangler, appeals the revocation of his probation, raising essentially the following issues: whether the trial court abused its discretion by finding that the defendant violated the terms of his probation by failing to submit to a drug screen and failing to pay court costs and fees when neither failure was willful; whether the trial court erred by not considering all lesser alternative means to incarceration, including intensive drug rehabilitation by referral to a drug court; and whether the trial judge committed plain error by not sua sponte recusing himself because he had been the prosecutor in a number of the defendant's previous criminal cases. Following our review, we affirm the judgment of the trial court.