Leslie Paul Hatfield appealed the Bledsoe County Circuit Court's partial denial of his petition for a writ of habeas corpus. He argued that his conviction for incest was void due to an illegal sentence of community supervision for life and claimed that his convictions for two counts of statutory rape, solicitation of a minor, and casual exchange of a controlled substance were void because he was not awarded all his pre-trial jail credits. The trial court granted habeas corpus relief for the incest charge but denied it for the other convictions. However, the appellate court found the statutory rape conviction reflected an illegal sentence and determined that pre-trial credits were improperly not applied to concurrent sentences. Consequently, the appellate court reversed the trial court's judgment and remanded the case to the Criminal Court for Scott County for corrected judgments. The original sentence included various probation terms for the offenses, with a total of 226 days of pre-trial jail credit noted for statutory rape, but this credit was not reflected in the concurrent judgments for the other charges.
The Petitioner filed a petition for writ of habeas corpus and supporting affidavit on March 15, 2009, but there is no evidence they were filed with the Bledsoe County Circuit Court. On May 20, 2009, the court granted the writ for the incest sentence, ruling that the imposition of lifetime community supervision was illegal as it is not authorized for that offense under T.C.A. 39-13-524(a). The case was remanded for a corrected judgment to remove this provision, although such a judgment is not present in the record. The trial court denied habeas corpus relief for the Petitioner’s other claims, indicating that any error regarding pre-trial jail credit should be addressed through the Uniform Administrative Procedures Act, not through a habeas corpus petition. On appeal, the Petitioner argued that the trial court erred by not awarding mandatory pre-trial jail credit for all concurrent sentences. The State contended that the application of jail credits is not a valid basis for habeas relief. The court agreed with the Petitioner, stating that habeas corpus relief is warranted when a judgment is void, which occurs when a court lacks jurisdiction or authority to impose a sentence. The burden is on the Petitioner to demonstrate, by a preponderance of the evidence, that the judgment is void. If successful, the Petitioner is entitled to immediate release. However, the trial court can dismiss a habeas petition without a hearing if it does not present a valid claim. The awarding of pre-trial jail credit is mandatory, and it is improper to grant credit for only one of multiple concurrent sentences when the defendant was held in pre-trial custody for all charges. The record indicates that the Petitioner was incarcerated from December 1, 2003, to July 13, 2004, but the judgments for counts 2, 5, and 7 did not grant the required pre-trial jail credits despite the sentences being served concurrently.
Judgments of conviction are deemed illegal due to the trial court's failure to award mandatory pre-trial jail credits, violating T.C.A. 40-23-101(c) and established case law (Hoover v. State). The state's claim that this issue is not cognizable in a habeas corpus proceeding is countered by the recognition that disputes over sentence reduction credits in the custody of the TDOC fall under the Administrative Procedures Act (Carroll v. Raney). The trial court is obligated to award pre-trial credits, and the TDOC lacks authority to alter such awards. Consequently, the failure to grant these credits rendered the judgments for counts 2, 5, and 7 void. Additionally, the judgment for count 1, sentencing the Petitioner to eight years of probation for a Class E felony conviction (statutory rape), is also void, as it exceeds the permissible sentencing range of one to two years for a Range I standard offender and the overall maximum of six years. While an illegal sentence does not invalidate a guilty plea, the issue of whether the plea agreement included an illegal sentence as a material element remains for the convicting court to resolve. The court reverses the trial court's judgment and remands the case for corrected judgments.
