State of Tennessee v. Jaymes Harrison
M2016-01875-CCA-R3-CD
| Tenn. Crim. App. | May 8, 2017Background
- Jaymes Harrison pleaded guilty in Oct. 2011 to aggravated sexual battery (Class B felony) after being charged with rape of a child (Class A); he received a 12-year sentence to be served at 100% as a Range I offender.
- An amended judgment corrected a clerical mistake; later (2016) Harrison filed a pro se Rule 36.1 motion to correct an alleged illegal sentence (motion not included in record).
- The trial court summarily denied the Rule 36.1 motion on August 29, 2016; Harrison timely appealed.
- Harrison’s principal contention: he should not have received the high-end (12-year) sentence because he had no qualifying prior convictions.
- The State moved to affirm under CCA Rule 20; the Court of Criminal Appeals granted the motion and affirmed the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 12-year, 100% sentence is illegal under Tenn. R. Crim. P. 36.1 | Harrison: sentence is improperly at the high end since he lacked qualifying priors | State/Trial Ct.: sentence was part of an agreed plea and is authorized by statute | Court: affirmed — sentence is authorized and not an "illegal" sentence under Rule 36.1 |
| Whether Rule 36.1 permits collateral attacks on plea validity or counsel effectiveness | Harrison: challenges to indictment/plea/counsel render sentence illegal | State/Trial Ct.: Rule 36.1 addresses only illegal sentences, not convictions or representation claims | Court: such challenges are not cognizable in a Rule 36.1 motion |
| Whether offender classification / release eligibility used in plea bargaining can render a sentence illegal | Harrison: implied challenge to classification/release terms | State: offender classification and release eligibility are legitimate plea-bargain subjects | Court: such negotiated terms are non-jurisdictional and valid when statutorily authorized |
| Whether the absence of the motion and plea in the record prevents resolution | Harrison: record omissions (motion, plea) | State: sufficient information exists to rule on merits | Court: had sufficient information and adjudicated the appeal |
Key Cases Cited
- State v. Brown, 479 S.W.3d 200 (Tenn. 2015) (Rule 36.1 permits correction of unexpired illegal sentences)
- State v. Wooden, 478 S.W.3d 585 (Tenn. 2015) (definition of illegal sentence under Rule 36.1 coextensive with habeas corpus standard; distinguishes clerical, appealable, and fatal errors)
- Bland v. Dukes, 97 S.W.3d 133 (Tenn. Crim. App. 2002) (offender classification and release eligibility may be negotiated in plea bargains)
- McConnell v. State, 12 S.W.3d 795 (Tenn. 2000) (offender classification and release eligibility are non-jurisdictional plea bargaining tools)