Steven Padgett King v. State of Tennessee, M2017-00058-CCA-R3-PC

In 2002 King pled guilty to especially aggravated kidnapping and aggravated rape; he received consecutive 20-year sentences served at 100% release eligibility.
Original judgments entered in 2004 did not include the statutorily required community supervision for life that applies to aggravated rape convictions.
The trial court, construing a Rule 36.1 motion and Derrick Brandon Bush, amended King’s judgment forms on August 25, 2016 to add community supervision for life.
King filed a pro se post-conviction petition on November 15, 2016, claiming his plea was not knowingly or intelligently entered because the life community supervision term was not part of his original plea.
The post-conviction court dismissed the petition as time-barred on December 20, 2016; King appealed.
The Court of Criminal Appeals held the amended judgment restarted the one-year post-conviction limitations period and therefore King’s November 2016 petition was timely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether King’s post-conviction petition was time-barred	King: the one-year limitations period began when the judgment was amended on Aug 25, 2016, so his Nov 15, 2016 petition is timely	State: the petition was untimely (post-conviction court found it time-barred)	The amended judgment reset the one-year limitations period; King’s petition was timely and dismissal reversed

Derrick Brandon Bush v. State, 428 S.W.3d 1 (Tenn. 2014) (addressing correction of illegal sentences and permitting amendment of judgments to reflect statutorily required sentencing components)