Sheddrick Harris v. State of Tennessee, E2016-01573-CCA-R3-HC

Petitioner Sheddrick Harris was indicted and convicted (jury) of first-degree murder and pleaded guilty to especially aggravated robbery; effective sentence: life without parole plus 60 years. Appellate and post-conviction proceedings followed.
Petitioner filed a habeas corpus petition asserting the trial judge had signed a search warrant (May 21, 2008) and later presided at Harris’s trial (Aug. 13, 2010), which, Petitioner claimed, deprived the trial court of jurisdiction.
Petitioner relied on Tenn. Code Ann. § 17-2-101 and Hamilton v. State to argue the judge’s prior action as a judicial officer created a conflict requiring disqualification.
The habeas court dismissed the petition, finding the judge signed the warrant and presided in his capacity as a criminal court judge and thus did not lack jurisdiction.
The court further explained that constitutional objections of the kind raised are typically cognizable in post-conviction proceedings (not habeas), and Hamilton addressed a constitutional violation remediable by new trial/post-conviction relief rather than rendering a judgment void.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial judge’s signing of a search warrant then presiding at trial deprived the court of jurisdiction, rendering the judgment void	Harris: judge signed warrant and then sat at trial, so judge was disqualified and conviction/judgment is void	State: judge acted as criminal court judge in both acts; no lack of jurisdiction; issue, if constitutional, is for post-conviction relief	Court: dismissal affirmed — judgment not void; judge had authority; habeas relief not available on this claim
Whether the claim is cognizable in habeas corpus rather than post-conviction proceedings	Harris: raised in habeas as jurisdictional defect	State: constitutional claims like this are for post-conviction, not habeas	Court: claim is cognizable in post-conviction; habeas improperly used; summary dismissal proper

Hamilton v. State, 403 S.W.2d 302 (Tenn. 1966) (addressed judge signing warrant in inferior capacity and later presiding; constitutional violation remediable by new trial)
Archer v. State, 851 S.W.2d 157 (Tenn. 1993) (void judgment exists where convicting court lacked jurisdiction or authority)
Summers v. State, 212 S.W.3d 251 (Tenn. 2007) (distinguishes void judgments from voidable ones requiring post-conviction proof)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (procedure for collateral attack on search-warrant affidavits)