State of Tennessee v. Quinton Cage
M2020-00360-CCA-R3-CD
| Tenn. Crim. App. | Jul 27, 2021Background
- In 1994 Quinton Cage was convicted in Montgomery County of aggravated rape, especially aggravated kidnapping, aggravated robbery, attempted aggravated robbery, and reckless endangerment and received an effective 55-year sentence.
- Cage has repeatedly sought post-conviction and habeas relief over many years without success.
- On January 24, 2020 Cage filed a Tennessee Rule of Criminal Procedure 36.1 motion to correct an illegal sentence, arguing his convictions violate double jeopardy and therefore the sentences are illegal.
- The trial court summarily dismissed the Rule 36.1 motion for failure to state a cognizable claim under Rule 36.1.
- Cage also moved under Tenn. R. App. P. 14 to have the Court of Criminal Appeals consider post-judgment facts (education certificates, prison program certificates, letters with trial counsel, mental-health results, trial motions). Most documents predated the trial court’s February 2020 order and did not bear on sentence illegality.
- The Court of Criminal Appeals denied the Rule 14 motion and affirmed the trial court, holding double jeopardy challenges are not cognizable via Rule 36.1.
Issues
| Issue | Cage's Argument | State's Argument | Held |
|---|---|---|---|
| Whether a double jeopardy claim can be raised in a Rule 36.1 motion to correct an illegal sentence | Cage: convictions violate double jeopardy, so sentences are illegal and trial court lacked jurisdiction | State: double jeopardy challenges are not cognizable under Rule 36.1; summary dismissal proper | Court: Double jeopardy claims are not cognizable in Rule 36.1 proceedings; affirmed dismissal |
| Whether the Court should consider the post-judgment facts Cage submitted under Tenn. R. App. P. 14 | Cage: submitted certificates, letters, mental-health results, and motions to be considered as post-judgment facts | State: the documents mostly predate the trial court’s order and do not affect whether the sentence is illegal; Rule 14 not for retrial of issues | Court: Denied; documents are not post-judgment facts bearing on sentence illegality |
Key Cases Cited
- State v. Wooden, 478 S.W.3d 585 (Tenn. 2015) (defines Rule 36.1 “illegal sentence” and explains the "colorable claim" pleading standard)
- Summers v. State, 212 S.W.3d 251 (Tenn. 2007) (legal standard: de novo review for whether a Rule 36.1 motion states a colorable claim)