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Timothy R. Chatmon v. State of Tennessee
Citation: Not availableDocket: E2013-00591-CCA-R3-HC
Court: Court of Criminal Appeals of Tennessee; October 15, 2013; Tennessee; State Appellate Court
Original Court Document: View Document
Timothy R. Chatmon filed a habeas corpus petition in the Hamilton County Criminal Court challenging his two convictions for possession of cocaine with intent to sell, both resulting in eight-year sentences. The habeas corpus court denied the petition, concluding that Chatmon was not entitled to relief as he was neither imprisoned nor restrained by the convictions, which had expired. The court determined that claims of ineffective assistance of counsel and involuntary guilty pleas constituted voidable judgments rather than void ones, categorizing them as post-conviction issues not suitable for habeas corpus relief. Additionally, even if the petition were interpreted as seeking post-conviction relief, it was barred by the statute of limitations. On appeal, the court affirmed the lower court's judgment, emphasizing that the petitioner carries the burden to show his sentence is void or his confinement illegal, and that habeas relief is limited to situations where a trial court lacked jurisdiction or a sentence has expired. Habeas corpus relief is only available for void judgments, not voidable ones, as established in Wyatt and Taylor. A void judgment occurs when the court lacked jurisdiction or authority, or the sentence has expired. A sentence imposed against statutory provisions is also considered void. The State contended that the petitioner did not meet procedural requirements for a habeas corpus petition, which are mandatory per Tennessee Code Annotated section 29-21-107. The petitioner failed to verify the application by affidavit, attach judgment copies, state that the legality of the restraint had not been previously adjudicated, and indicate that it was the first application for the writ. However, since the lower court did not deny the petition on procedural grounds, the court chose not to do so either. To qualify for habeas corpus relief, a petitioner must be "imprisoned or restrained of liberty" by the challenged convictions. Those detained due to federal convictions do not qualify for state habeas review. Additionally, individuals are not considered restrained by convictions for which they have completed their sentences. The petitioner, currently incarcerated for a federal offense, has fully served his sentences from the challenged judgments, which have expired, thus rendering his claims unviable. Claims regarding ineffective counsel or plea voluntariness would at most make the judgments voidable, which are not grounds for habeas corpus relief. Consequently, the court affirmed the habeas corpus court's judgment, denying the petitioner relief.