David CANTRELL v. Joe EASTERLING, Warden, 346 S.W.3d 445

In 1995, Cantrell was convicted by a jury of four counts of aggravated rape and one count of false imprisonment; he received four consecutive 40-year terms with an effective 80-year term.
Each of Cantrell’s four judgments designated him as a “Multiple 35% Range 2” offender but none designated him as a “Multiple Rapist.”
Tennessee law (39-13-523) prohibits parole or REDs for multiple rapists, requiring service of the full sentence; the REDs on Cantrell’s judgments contravene this statute.
TDOC must enforce judgments as written and cannot correct the judgments unilaterally when they violate statute.
The trial court’s designation created four illegal and void sentences; Cantrell’s underlying convictions remain intact, and the Court remands for amended judgments reflecting “Multiple Rapist.”
The case traces prior habeas practice and establishes that illegal sentences may be corrected by habeas corpus when they directly contravene statutes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the RED designation rendered Cantrell’s sentences illegal	Cantrell (Cantrell) argues REDs violate 39-13-523.	State argues error is clerical or non-jurisdictional.	Yes; REDs were not authorized and sentences are illegal.
Whether the four judgments incorrectly imply parole eligibility	Cantrell was not eligible for parole as a multiple rapist.	Judgments reflected a clerical error; not a void sentence.	Indeed, judgments improperly allowed parole eligibility; sentences void.
Appropriate remedy and effect on convictions	Cantrell should be remanded for corrected judgments; convictions stand.	Remand or direct-appeal could address classifications.	Habeas relief granted; remand for amended judgments reflecting “Multiple Rapist.” Convictions remain valid.
Relation to Edwards line of cases and non-jurisdictional errors	Edwards supports treating misclassifications as not voidable, or at least distinguishable.	Edwards governs non-jurisdictional errors after conviction.	The Court rejects rigid Edwards expansion; focuses on direct statutory contravention to render sentences void.

Burkhart v. State, 566 S.W.2d 871 (Tenn. 1978) (illegal sentence may be corrected as a nullity when in direct contravention of statute)
Moody v. State, 160 S.W.3d 512 (Tenn. 2005) (established habeas corpus procedure for illegal sentences)
Smith v. Lewis, 202 S.W.3d 124 (Tenn. 2006) (illegality may void only the sentence; conviction can remain intact)
Edwards v. State, 269 S.W.3d 915 (Tenn. 2008) (non-jurisdictional nature of offender classification and REDs in certain contexts)
Hoover v. State, 215 S.W.3d 776 (Tenn. 2007) (plea-bargained offender classification and REDs may be non-jurisdictional)
McConnell v. State, 12 S.W.3d 795 (Tenn. 2000) (limits on plea-bargain-based sentencing irregularities; years within statutory range)
Davis v. State, 313 S.W.3d 751 (Tenn. 2010) (non-jurisdictional nature of release eligibility determinations in plea bargains)
Summers v. State, 212 S.W.3d 251 (Tenn. 2007) (requirements for record support when illegality not facially apparent)
Stephenson v. Carlton, 28 S.W.3d 910 (Tenn. 2000) (context of illegal sentences and correct remedy in some cases)