Patrick Stewart appeals the denial of his habeas corpus petition by the Lauderdale County Circuit Court, which was presided over by Judge Joe H. Walker. Stewart had previously entered guilty pleas to first-degree murder and aggravated rape in 1991, receiving concurrent sentences of life imprisonment and fifteen years, respectively. His habeas corpus petition, filed on May 30, 2005, claimed that his sentence was void due to the trial court's alleged failure to comply with Rule 11 of the Tennessee Rules of Criminal Procedure, which he argued invalidated the court's jurisdiction to accept his guilty plea.
The trial court denied the petition on June 30, 2005, citing Stewart's failure to attach a copy of the judgment to his petition, a procedural requirement mandated by T.C.A. 29-21-107(b)(2). The court also found that Stewart's sentences had not expired and that the criminal court had the authority to impose the sentences. Additionally, the court noted that if the petition were construed as one for post-conviction relief, it would be time-barred.
The State filed a motion to affirm the trial court's ruling based on Stewart's failure to present a colorable claim and his noncompliance with procedural requirements. Stewart responded by attaching copies of his judgments, but the court determined that this attempt to correct the initial deficiency was untimely. Ultimately, the Court of Criminal Appeals affirmed the trial court's dismissal of the habeas corpus petition, emphasizing that the procedural rules for such petitions must be strictly followed.
The appellate court is limited to reviewing the habeas court's decision regarding the dismissal of the petitioner’s claim. Habeas corpus relief in this jurisdiction is applicable only for detentions stemming from void judgments or expired sentences. A judgment is considered void if the convicting court lacked jurisdiction or if the sentence has expired, which must be evident from the judgment or record. The petitioner has the burden to prove a void judgment or illegal confinement by a preponderance of the evidence. If the allegations do not show a void judgment, the trial court can dismiss the petition without a hearing. In this case, the petitioner did not claim that his sentence had expired and failed to demonstrate any grounds for a void judgment. The claim regarding non-compliance with procedural rules does not constitute a void judgment but rather a potentially voidable one. The trial court treated the petition as both a habeas corpus application and a post-conviction petition, finding it time-barred since it was filed outside the statute of limitations. No exceptions to this limitation were applicable. Consequently, the trial court's dismissal of the petition was upheld, affirming that the petition did not allege a valid ground for habeas corpus relief and was also time-barred as a post-conviction relief application. The State's motion is granted, and the trial court's judgment is affirmed.
