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Eric Carter v. Glen Turner, Warden and State of Tennessee

Citation: Not availableDocket: W2006-01114-CCA-R3-HC

Court: Court of Criminal Appeals of Tennessee; February 15, 2007; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves an appeal by a petitioner seeking habeas corpus relief, reviewed by the Court of Criminal Appeals of Tennessee. The petitioner, previously convicted of second-degree murder and sentenced to twenty-four years, argued the judgment was void due to a failure to account for pretrial jail credit. The Circuit Court for Hardeman County denied the petition, finding the claim related to jail credit would render the judgment voidable, not void, under Tennessee law. The petitioner had also been unsuccessful in a prior post-conviction relief attempt, which was dismissed as time-barred. Upon review, the appellate court upheld the lower court's decision, emphasizing that habeas corpus relief in Tennessee is limited to challenging void judgments or expired sentences. The court concluded that the petition did not demonstrate an illegal sentence or void judgment, thus affirming the trial court's denial of the habeas corpus petition and granting the State's motion to affirm.

Legal Issues Addressed

Appellate Review of Habeas Corpus Denial

Application: The appellate court affirmed the trial court's decision, finding no basis for habeas relief as the petition failed to establish grounds for a void judgment or illegal sentence.

Reasoning: The court affirmed the trial court's judgment, concluding that Carter's petition did not present a cognizable claim for relief.

Habeas Corpus Relief in Tennessee

Application: The court examined the requirements for a cognizable habeas corpus claim, emphasizing that the petition must demonstrate a void judgment or an illegal sentence.

Reasoning: The court emphasized that a habeas corpus petition can only challenge void judgments or seek immediate release due to expired sentences.

Void vs. Voidable Judgments

Application: The court determined that the alleged omission of pretrial jail credit did not render the judgment void, but rather voidable under Tennessee law.

Reasoning: The trial court determined that even if his claim regarding jail credit was valid, it would not render the judgment void but rather voidable, as per Tennessee law.