Quinton A. Cage appealed the denial of his application to reopen his post-conviction relief petition, claiming he was incompetent when the original petition was filed. The post-conviction court dismissed the motion, and the appeal was subsequently deemed untimely and dismissed. Cage had been convicted of multiple serious offenses in 1994, including aggravated rape and especially aggravated kidnapping, receiving consecutive sentences totaling up to twenty-five years. Following his conviction, he filed a post-conviction relief petition in 2000, claiming ineffective assistance of counsel, which was denied and affirmed on appeal. In 2007, he sought a writ of habeas corpus, asserting double jeopardy violations, but this was also dismissed. In 2009, Cage filed a pro se writ of error coram nobis, alleging issues with his trial process and the counsel's advice regarding his plea. He later requested to convert this into a motion to reopen his post-conviction proceedings, arguing his mental incompetence hindered his ability to understand and manage his legal affairs, thus necessitating the tolling of the statute of limitations for his claims.
The petitioner provided an affidavit from Dr. Casey C. Arney, a psychiatrist, who treated him from 1999 to 2004 and diagnosed him with paranoid schizophrenia. Dr. Arney stated that the petitioner was placed under conservatorship on January 28, 2003, for involuntary treatment and opined that the petitioner was unable to assist in his legal defense during that period due to mental illness. The post-conviction court initially allowed the petition to be treated as a motion to reopen but ultimately denied it, stating that the petitioner’s claims of mental incompetence did not meet the statutory requirements for reopening post-conviction proceedings. The court referenced Tennessee Supreme Court precedent indicating there is no constitutional or statutory right to competency in such proceedings. It acknowledged that while a statute of limitations for filing a post-conviction petition may be tolled due to mental incompetence, the petitioner failed to provide prima facie evidence of incompetence after 2004. The court deemed the claims presented as unsupported or general allegations. The State contended that the appeal was not timely filed, noting that the petitioner had ten days from the denial of the motion to reopen to seek an interlocutory appeal. Since the petitioner filed his notice of appeal 28 days after the denial, the court ruled it lacked jurisdiction over the appeal due to untimeliness and dismissed it.
