Courtney R. Logan v. Shawn Phillips, Warden
E2016-01535-CCA-R3-HC
| Tenn. Crim. App. | May 26, 2017Background
- In 2009 Courtney R. Logan aided an escape in Mississippi and fled to Tennessee; during the flight his cousin shot an officer in Tennessee. Logan was later convicted in Tennessee and given an effective 31-year sentence.
- Mississippi tried and convicted Logan on multiple kidnapping and related charges arising from the escape and sentenced him as a habitual offender to seven consecutive life terms without parole; he is incarcerated in Mississippi.
- In March 2015 Logan filed habeas petitions in Davidson County and then in Morgan County challenging his extradition to Mississippi; the Morgan County petition was substantially identical to the earlier filings.
- The Davidson County petition was summarily dismissed and affirmed on appeal as moot because Logan had already been extradited, tried, and convicted in Mississippi and was no longer in Tennessee custody.
- At the Morgan County habeas hearing counsel conceded the practical effect of the prior decision; the habeas court dismissed Logan’s petition for mootness, and Logan appealed.
- The Tennessee Court of Criminal Appeals affirmed, holding that once a person has been returned to the demanding state a challenge to extradition in the asylum state is moot and no relief is available.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a habeas challenge to Tennessee extradition is justiciable after the defendant has been returned to the demanding state | Logan contended he could challenge the legality of his extradition to Mississippi | State argued the challenge is moot because Logan is no longer in Tennessee custody and has been tried and convicted in Mississippi | Dismissed as moot; court affirmed that challenges to extradition become moot once the fugitive is returned |
| Whether the habeas court erred in summarily dismissing the petition | Logan maintained the habeas petition should be considered despite prior dismissals elsewhere | State relied on precedent and the absence of available relief to defend dismissal | Court found no error in dismissal for mootness |
Key Cases Cited
- Logan v. State, 192 So. 3d 1012 (Miss. Ct. App. 2015) (affirming convictions in Mississippi arising from the escape)
- Barton v. Norrod, 106 F.3d 1289 (6th Cir. 1997) (holding extradition challenges become moot once the fugitive is returned to the demanding state)