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State v. Felts

Citation: Not availableDocket: 03C01-9708-CR-00333

Court: Court of Criminal Appeals of Tennessee; March 25, 1998; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the appellant, serving a 23-year sentence for aggravated sexual battery and rape of a child, appealed the summary denial of his habeas corpus petition by the Morgan County Criminal Court. The appellant contended that his indictments were deficient for failing to allege a culpable mens rea and that he was entitled to appointed counsel and a hearing. The appellate court affirmed the lower court's decision, referencing the appellant's responsibility to include the relevant indictments in the record. In their absence, the appellate court presumed the trial court's decisions were supported by sufficient evidence. Additionally, the court clarified that the Habeas Corpus Act does not necessitate the appointment of counsel or a hearing if the petition does not make a valid claim for relief. As such, the dismissal of the appellant's petition was upheld, with the appellate court finding no errors in the lower court's proceedings.

Legal Issues Addressed

Appointment of Counsel in Habeas Corpus Proceedings

Application: The court held that the Habeas Corpus Act does not mandate the appointment of counsel or require a hearing if the petition does not present a valid claim for relief.

Reasoning: The court highlights that the Habeas Corpus Act does not require the appointment of counsel or a hearing if the petition does not present a valid claim for relief.

Habeas Corpus Petition Requirements

Application: The court determined that the appellant's failure to include relevant indictments in the record meant the court must presume the trial court's decisions were supported by sufficient evidence.

Reasoning: Without these documents, the court presumes the trial court's decisions were supported by sufficient evidence.