Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Jeffrey Henry v. State of Tennessee
Citation: Not availableDocket: W2016-02435-CCA-R3-ECN
Court: Court of Criminal Appeals of Tennessee; November 13, 2017; Tennessee; State Appellate Court
Original Court Document: View Document
Jeffrey Henry pled guilty in 2015 to three counts of aggravated sexual battery, receiving a twenty-year sentence. In September 2016, he filed an untimely petition for writ of error coram nobis, claiming newly discovered evidence regarding the victim's medication for oppositional defiant disorder, which he argued could undermine the validity of his guilty pleas. He also contended that a Tennessee Supreme Court decision (Frazier v. State) violated his due process rights, claiming it tolled the one-year statute of limitations for his petition. The coram nobis court dismissed the petition, stating that, following the Frazier ruling, a guilty plea cannot be collaterally attacked via the coram nobis statute. The court noted that Henry had previously acknowledged awareness of the victim's mental health treatment, indicating that the evidence he presented was not newly discovered, thus rendering his petition untimely. The Court of Criminal Appeals affirmed the coram nobis court's decision, agreeing that it lacked the authority to reinterpret the Frazier ruling and that Henry's prior knowledge of the victim’s condition negated his claims. The case was affirmed under Rule 20, which allows for summary affirmance when the judgment is not a determination of guilt and the evidence does not contradict the trial court's findings.