State of Tennessee v. Paul Samuel Eslinger, E2015-02126-CCA-R3-CD

Paul Eslinger was indicted in three Sevier County cases for sales/delivery of Schedule I and II controlled substances (offense dates Apr–Oct 2012).
The State filed notice seeking enhanced punishment, alleging Eslinger was a career offender; his criminal history was attached.
Eslinger entered a plea agreement pleading guilty to three sale counts: two Class C felonies (Schedule II) and one Class B felony (Schedule I); delivery counts were dismissed.
The written plea and plea colloquy specified three concurrent 30-year sentences with 45% release eligibility; Eslinger later claimed he believed the agreed term was 13 years at 45%.
Eslinger filed a motion to withdraw his guilty pleas after sentencing; the trial court denied the motion. He appealed.
On appeal the Court of Criminal Appeals found the negotiated 30-year terms for the Class C felonies exceeded the statutory maximum and were illegal; concurrent sentencing also conflicted with the statute requiring consecutive sentences when a felony is committed while released on bond.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Eslinger’s guilty pleas were involuntary/unknowing because he thought sentence would be 13 years	State: plea colloquy and written agreement show 30-year term; plea was knowing and voluntary	Eslinger: counsel told him sentence was 13 years; he is illiterate and relied on counsel	The court rejected Eslinger’s voluntariness claim — record shows agreed 30-year term
Whether the negotiated 30-year sentences for Class C felonies were lawful	State: package plea authorized overall; relied on plea agreement	Eslinger: argued plea should be withdrawn (post-sentencing) based on misunderstanding and manifest injustice	Court held 30 years for Class C felonies exceeded statutory maximum (15 years) and were illegal; manifest injustice warranted withdrawal of pleas
Whether the trial court exceeded jurisdiction by accepting illegal sentences	State: did not raise illegality; relied on plea agreement	Eslinger: sought withdrawal of plea (raising illegality)	Court held sentencing beyond statutory limits exceeded court’s jurisdiction and is a nullity
Whether sentences should have run concurrently given defendant committed a felony while on bond	State: negotiated concurrent sentences	Eslinger: concurrent sentences per plea	Court held concurrent alignment was erroneous because statute mandates consecutive sentences when felony committed while released on bond

State v. Phelps, 329 S.W.3d 436 (Tenn. 2010) (standard and burden for withdrawing guilty plea; appellate review is abuse of discretion)
State v. Crowe, 168 S.W.3d 731 (Tenn. 2005) (manifest injustice standard and limits on post-sentencing plea withdrawal)
McConnell v. State, 12 S.W.3d 795 (Tenn. 2000) (1989 Sentencing Act sets outer statutory limits; parties cannot agree to sentences beyond statutory maximums)
Davis v. State, 313 S.W.3d 751 (Tenn. 2010) (unauthorized sentences that contravene statute are illegal and a nullity)
Kadwell v. United States, 315 F.2d 667 (9th Cir. 1963) (quoted on public interest in protecting right to jury trial and cautions against facile plea withdrawal)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s duty to disclose exculpatory evidence; nondisclosure can affect plea validity)