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State of Tennessee v. Earl Junior Pike
Citation: Not availableDocket: M2015-01573-CCA-R3-CD
Court: Court of Criminal Appeals of Tennessee; July 11, 2016; Tennessee; State Appellate Court
Original Court Document: View Document
Earl Junior Pike appeals the trial court's denial of his motion to correct an illegal sentence under Tennessee Rule of Criminal Procedure 36.1. Pike, convicted in 1998 for aggravated sexual battery and rape of a child, received a twelve-year sentence for aggravated sexual battery and a twenty-five-year sentence for rape, served consecutively. He argued that both sentences should merge under the "24-hour merger rule," claiming the offenses occurred against one victim on a single day. The trial court found Pike's sentences legal, clarifying that the cited rule pertains to prior convictions' definitions under the Sentencing Act, not consecutive sentencing. The court emphasized that Pike's sentences were consistent with Tennessee law and that he failed to present a valid claim under Rule 36.1. The appellate court affirmed the trial court's decision, noting that an "illegal sentence" must be one not authorized by law or that violates applicable statutes. It reiterated that only fatal errors can render a sentence illegal, which was not the case here. Additionally, Pike's new argument regarding double jeopardy was waived as it had not been raised in the trial court. The appellate court concluded that Rule 36.1 allows for the correction of illegal sentences but does not provide grounds to reverse convictions, thus upholding the trial court's ruling.