State of Tennessee v. Felicia Annette Mitchell, E2015-01822-CCA-R3-CD

Felicia Annette Mitchell pleaded guilty in October 2013 to various drug offenses and received an effective five-year sentence.
On August 27, 2015, Mitchell filed a pro se motion to correct illegal sentences under Tenn. R. Crim. P. 36.1, alleging her pleas were not knowingly and voluntarily entered.
The trial court summarily denied the motion the same day, finding it untimely if treated as a post-conviction petition and that it failed to state a colorable claim under Rule 36.1.
Mitchell timely appealed the summary dismissal to the Tennessee Court of Criminal Appeals.
The State moved to affirm under Court of Criminal Appeals Rule 20; the appellate court reviewed whether Mitchell’s claim constituted a colorable Rule 36.1 claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mitchell’s claim that her guilty pleas were not knowingly and voluntarily entered states a colorable claim under Tenn. R. Crim. P. 36.1	Mitchell argued her sentences are illegal because her pleas were not knowing and voluntary, so Rule 36.1 relief is warranted	The State argued the claim challenges plea validity (an appealable error), and does not allege a fatal sentencing defect under Rule 36.1	Court held plea-voluntariness is an appealable error, not a Rule 36.1 illegal-sentence (fatal) claim; summary dismissal affirmed

State v. Wooden, 478 S.W.3d 585 (Tenn. 2015) (defines “colorable claim” under Rule 36.1 and distinguishes fatal illegal-sentence errors from appealable sentencing errors)
State v. Cantrell, 346 S.W.2d 445 (Tenn. 2011) (explains that only fatal errors render a sentence illegal and contrasts those with appealable errors)