Jeffery Yates v. State of Tennessee
2012 Tenn. Crim. App. LEXIS 29
| Tenn. Crim. App. | 2012Background
- Yates was convicted in Shelby County Criminal Court of aggravated robbery, a Class B felony, and sentenced to 30 years as a Range III career offender based on multiple prior felonies.
- Judgment credited pretrial confinement from September 22, 2001, to June 19, 2003 (636 days); post-judgment jail credit is not shown on the judgment.
- Yates filed a habeas petition asserting the conviction was void for lack of post-judgment jail credit and for reliance on a void prior conviction to classify him as a Range III offender.
- The circuit court summarily dismissed, ruling it lacked authority to amend or set aside a Shelby County judgment and directing TDOC channels for jail-credit concerns.
- The Court of Criminal Appeals affirmed, holding post-judgment jail credit claims are not cognizable in habeas corpus and offender-classification errors are not remedied on habeas review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas relief was proper without an evidentiary hearing on post-judgment jail credit | Yates contends post-judgment jail credit was improperly omitted. | State asserts pretrial credits only; habeas relief not warranted for post-judgment credit. | Denied; post-judgment jail credit not cognizable in habeas corpus. |
| Whether the sentence is void due to reliance on an invalid prior conviction for Range III classification | Yates challenges the validity of the prior convictions used for offense classification. | State contends offender classification is factual and not susceptible to habeas relief without specific, cognizable error. | Denied; offender-classification errors are not voiding errors cognizable in habeas petitions. |
Key Cases Cited
- Summers v. State, 212 S.W.3d 251 (Tenn. 2007) (void judgment standard; authority to void)
- Cantrell v. Easterling, 346 S.W.3d 445 (Tenn. 2011) (offender classification and habeas scope)
- Archer v. State, 851 S.W.2d 157 (Tenn. 1993) (habeas corpus limits; void vs voidable)
- Taylor v. State, 995 S.W.2d 78 (Tenn. 1999) (habeas purposes; void judgments)
- Kuntz v. Bomar, 381 S.W.2d 290 (Tenn. 1964) (burden on petitioner to show void judgment or expired sentence)
- Shorts v. Bartholomew, 278 S.W.3d 268 (Tenn. 2009) (TDOC authority over prisoners and post-judgment credits)
- Tucker v. Morrow, 335 S.W.3d 116 (Tenn. Crim. App. 2009) (distinguishes pretrial vs post-judgment credits; habeas scope)
- Herbert N. Jackson v. Tony Parker, No. W2010-01630-CCA-R3-HC (Tenn. Crim. App. 2011) (cited regarding post-judgment credits not cognizable)