Jackson Martin v. State of Tennessee
W2016-01388-CCA-R3-PC
| Tenn. Crim. App. | Jun 7, 2017Background
- Jackson Martin was convicted by a Shelby County jury of attempted second-degree murder and two counts of carjacking and received an effective 22-year sentence.
- This Court affirmed his convictions on direct appeal on February 1, 2013; Martin did not seek review in the Tennessee Supreme Court.
- Martin filed a pro se post-conviction petition on March 5, 2014 (just over one year after the direct-appeal decision) arguing ineffective assistance of counsel for failing to file an alibi notice and to call certain witnesses.
- The trial court appointed counsel, treated the petition as timely, held an evidentiary hearing, and denied relief on the merits.
- On appeal, the State argued (for the first time) the petition was untimely under Tenn. Code Ann. § 40-30-102(a); the Court concluded the petition was time-barred and dismissed the appeal for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martin's post-conviction petition was timely under the one-year statute of limitations | Martin contended his petition was timely, asserting his judgment became final later (misstating the finality date) | State argued the petition was filed after the one-year deadline and thus untimely, depriving the court of jurisdiction | Petition was untimely; one-year period ran from Feb 1, 2013 to Feb 1, 2014; petition filed March 5, 2014, so dismissed |
| Whether the trial court retained jurisdiction despite failing to raise timeliness below | Martin relied on the trial court’s treatment of the petition as timely and adjudication on the merits | State asserted timeliness is jurisdictional and can be raised on appeal even if not raised below | Timeliness is jurisdictional; lack of timely filing deprives courts of jurisdiction regardless of waiver below |
| Whether any statutory exceptions or due-process tolling applied to save the petition | Martin argued factual circumstances (e.g., misunderstanding) excused or tolled limitations | State argued none of § 40-30-102(b)’s exceptions applied and Williams due-process tolling was not implicated | No statutory exceptions applied; no due-process tolling warranted; petition barred |
| Whether ineffective-assistance claims should be reached on the merits despite timeliness issue | Martin urged ineffective assistance (alibi notice, witness failures) | State maintained merits cannot be reached because of jurisdictional time bar | Court declined to reach merits due to lack of jurisdiction resulting from untimely filing |
Key Cases Cited
- Williams v. State, 44 S.W.3d 464 (Tenn. 2001) (limited due-process tolling of post-conviction statute where strict application denies reasonable opportunity to file)
- Burford v. State, 845 S.W.2d 204 (Tenn. 1992) (earlier Tennessee decision recognizing due-process tolling in exceptional circumstances)
- Seals v. State, 23 S.W.3d 272 (Tenn. 2000) (discussing when a petitioner is denied reasonable opportunity to assert post-conviction claims)