Joseph Miles v. State of Tennessee, M2017-00349-CCA-R3-HC

Joseph Miles was convicted of second-degree murder in 1998 and sentenced to 40 years as a Range II offender; the conviction and sentence were affirmed on direct appeal.
Miles repeatedly sought post-conviction and collateral relief over many years (post-conviction, habeas, coram nobis), all unsuccessful.
In July 2015 Miles filed a second habeas corpus petition asserting Tennessee law does not authorize county grand juries and that his indictment was therefore void because jurors were selected only from Robertson County rather than from both counties in the Nineteenth Judicial District.
The habeas court denied relief on January 12, 2017, finding county grand juries lawful.
Miles also raised claims of police/prosecutorial/trial counsel misconduct on appeal, but those claims were not presented in his habeas petition below and were treated as waived.
The Court of Criminal Appeals affirmed the habeas court’s denial by memorandum opinion, concluding Miles failed to show his judgment was void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Grand jury composition	Miles: Indicting grand jury was invalid because jurors were drawn only from Robertson County, not from both counties in the 19th Judicial District, violating Tenn. Code Ann. §§ 16-2-506 & 16-2-510(c)	State: Selection from a single county in a multi-county judicial district does not render indictments void; controlling precedent rejects this claim	Court rejected Miles’s claim and held county grand juries are lawful for these purposes; no habeas relief.
Alleged misconduct by police, prosecutor, trial counsel	Miles: Misconduct undermines conviction	State: Not raised in the habeas petition below; procedural default/waiver	Court held the misconduct claims are waived because they were not pleaded in the habeas petition; no relief.

Edwards v. State, 269 S.W.3d 915 (Tenn. 2008) (habeas review is narrow and reviewed de novo)
Archer v. State, 851 S.W.2d 157 (Tenn. 1993) (habeas corpus in Tennessee is a narrow procedure; relief only for void, not voidable, judgments)
Hogan v. Mills, 168 S.W.3d 753 (Tenn. 2005) (distinguishing void from voidable judgments for habeas relief)
Summers v. State, 212 S.W.3d 251 (Tenn. 2007) (void judgment is facially invalid for lack of statutory authority)
State ex rel. Anglin v. Mitchell, 575 S.W.2d 284 (Tenn. 1978) (jurisdictional inquiry governs whether a judgment is void)
State v. Galloway, 45 Tenn. 326 (Tenn. 1868) (habeas relief is appropriate only when lack of jurisdiction appears on the face of the record)