State of Tennessee v. Lamar Fletcher, W2024-01869-CCA-R3-CD

In December 1975, Lamar Fletcher pleaded guilty to several offenses, including grand larceny, murder, and assault with intent to commit murder, resulting in concurrent sentences totaling ten years.
In 1985, Fletcher was convicted of two counts of robbery with a deadly weapon and two counts as a habitual criminal, receiving two concurrent life sentences.
Fletcher's habitual criminal status was supported by previous convictions, which went unchallenged during appeal and retrial.
He has subsequently filed multiple post-conviction and collateral attacks, all denied as time-barred or procedurally deficient.
In April 2023, Fletcher filed a Rule 36.1 motion to correct an illegal sentence, arguing concurrent sentencing was illegal as he was on bail during the offenses.
The trial court summarily dismissed the motion for procedural deficiencies and lack of a colorable claim; the appeal ensued.

Issue	Fletcher's Argument	State's Argument	Held
Whether the 1975 concurrent sentences were illegally imposed	Sentences were illegal because he was on bail and ineligible for concurrency	Motion was procedurally deficient and fails to state a claim	No colorable claim; sentences expired and benefited Fletcher
Whether procedural deficiencies warranted summary dismissal	Summary dismissal was improper despite missing documents	Motion lacked required judgment attachments and first-motion statement	Procedural errors alone justify summary denial
Whether expired sentences can be challenged under Rule 36.1	Illegal sentences can be corrected regardless of expiration	Rule 36.1 applies only to unexpired sentences	Cannot challenge expired sentences under Rule 36.1
Whether defendant benefitting from illegal sentence bars relief	Illegal concurrent sentence should nonetheless be corrected	Defendant cannot receive relief for errors that benefited him	Defendant not entitled to relief as error benefited him

Fletcher v. State, 951 S.W.2d 378 (Tenn. 1997) (pertinent to procedural history and prior post-conviction action)
Wooden v. State, 478 S.W.3d 585 (Tenn. 2015) (defining colorable claim under Rule 36.1)