Tracy Rose Baker v. State of Tennessee
417 S.W.3d 428
| Tenn. | 2013Background
- Tracy Rose Baker and her ex-husband engaged in post-divorce contempt litigation; Baker signed an Agreed Order (April 16, 2010) admitting guilt to eighteen counts of criminal contempt under Tenn. Code Ann. § 29-9-102 and agreeing to consecutive 10-day terms (180 days total), suspended on probation.
- After alleged probation violations, the trial court revoked probation and ordered 180 days in jail (later reduced to 30 days on appeal to the Court of Appeals).
- Baker filed a petition for post-conviction relief challenging the Agreed Order on grounds including Boykin/Mackey defects in plea-taking, judicial bias, and improper role of husband’s lawyer as private prosecutor.
- The trial court dismissed the post-conviction petition; the Court of Criminal Appeals affirmed, holding that a § 29-9-102 contempt adjudication is not a criminal conviction under the Post-Conviction Procedure Act (PCPA).
- The Tennessee Supreme Court granted permission to appeal to decide whether a criminal contempt adjudication under § 29-9-102 qualifies as a "conviction" eligible for relief under the PCPA and affirmed the lower courts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a § 29-9-102 criminal contempt adjudication is a "conviction" for purposes of the Post-Conviction Procedure Act | Baker argued the Agreed Order represented criminal convictions (pleas) subject to post-conviction review (Boykin/Mackey defects) | State argued general contempt under § 29-9-102 is sui generis, not a conviction of a criminal offense under the general criminal laws, so the PCPA does not apply | Held: § 29-9-102 contempt findings are not criminal convictions for PCPA purposes; post-conviction relief is unavailable |
| Whether post-conviction procedural safeguards apply to § 29-9-102 contempts | Baker contended Boykin/Mackey plea protections should apply and entitle her to PCPA relief | State contended contempt proceedings are distinct and only certain constitutional protections apply; PCPA scope is limited to convictions of criminal offenses | Held: Contempt proceedings afford some criminal-type protections, but that does not convert a § 29-9-102 contempt into a criminal conviction for PCPA relief |
| Whether PCPA jurisdictional/venue/party requirements were satisfied (naming State, DA response) | Baker relied on filing her PCPA petition in custody and asserting constitutional defects | State noted PCPA requires petitions be filed in the court of conviction, name the State, and obligates district attorneys to respond to PCPA petitions for criminal convictions | Held: Because the contempt adjudication is not a PCPA-qualifying conviction, those PCPA requirements and remedies do not apply |
| Remedies available to challenge contempt adjudication from civil case | Baker argued PCPA was proper vehicle to challenge Agreed Order convictions/sentences | State argued civil rules (Tenn. R. Civ. P. 59, 60) and direct appeals are the appropriate avenues to attack civil judgments and contempt orders | Held: Relief from general contempt findings in civil cases must be sought under civil appellate and procedural rules, not the PCPA |
Key Cases Cited
- Boykin v. Alabama, 395 U.S. 238 (establishes plea-taking requirements for criminal convictions)
- Mackey v. State, 553 S.W.2d 337 (Tenn.) (Tennessee precedent on plea safeguards in contempt/plea contexts)
- Gompers v. Buck’s Stove & Range Co., 221 U.S. 418 (describes civil vs. criminal contempt purposes)
- Bagwell v. Int’l Union, 512 U.S. 821 (distinguishes civil and criminal contempt; jury trial and punitive sanction analysis)
- Black v. Blount, 938 S.W.2d 394 (Tenn.) (discusses private prosecutors and contempt proceedings)
- Beeler v. State, 387 S.W.3d 511 (Tenn.) (analysis of contempt powers and classification)
- Brown v. Latham, 914 S.W.2d 887 (Tenn.) (recognizes when contempt conduct is also a statutory criminal offense)
- Long v. McAllister-Long, 221 S.W.3d 1 (Tenn.) (contempt sanctions and proof-beyond-reasonable-doubt discussion)
- State v. Burdin, 924 S.W.2d 82 (Tenn.) (statutory definition of criminal offenses)