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Sedrick Williams v. State of Tennessee
Citation: Not availableDocket: W2013-02401-CCA-R3-HC
Court: Court of Criminal Appeals of Tennessee; April 9, 2014; Tennessee; State Appellate Court
Original Court Document: View Document
Sedrick Williams appeals the dismissal of his habeas corpus petition by the Lauderdale County Circuit Court, which denied his claim that his conviction for first-degree premeditated murder is facially void due to a lack of notation that he must serve 100% of his sentence as a "100% violent offender." Williams argues that this omission renders his sentence illegal. The appellate court affirms the lower court's decision, noting that habeas corpus relief is limited to situations where a judgment is void due to the trial court lacking jurisdiction or authority, or when a sentence has expired. The court emphasizes that a void judgment is one that is invalid on its face, and that Williams bears the burden of proving the sentence's invalidity. Additionally, the State contends the appeal should be dismissed as untimely since Williams filed his notice of appeal more than 30 days after the dismissal order. The court upholds the dismissal based on both the substantive legal standards for habeas relief and the procedural issue of the untimely appeal. Rule 4(a) allows for the waiver of the filing requirement for a notice of appeal in criminal cases, which has been applied in this instance to address the Petitioner's concerns. The Petitioner was convicted of first-degree murder and sentenced to life imprisonment. He contends that the trial court's failure to check the 'Violent 100' box on his judgment form renders his judgment void. However, the court disagrees, noting that the Petitioner committed his offenses on October 10, 1997, and according to Tennessee Code Annotated section 40-35-501(i)(1), there is no release eligibility for those committing first-degree murder after July 1, 1995. The judgment form lists various release eligibility options but does not conflict with the statutes, as it specifically states the Petitioner’s eligibility regarding first-degree murder without providing a percentage. Thus, the life sentence complies with statutory law, and the Petitioner is not entitled to habeas corpus relief. The habeas corpus court's denial of the petition is affirmed.