William Reynolds v. Cherry Lindamood, Warden
M2016-01312-CCA-R3-HC
| Tenn. Crim. App. | Nov 7, 2016Background
- Petitioner William Reynolds was indicted for sale of cocaine in a drug-free school zone (charged as less than .5 grams, classified as a Class B felony because of the school-zone enhancement).
- Pursuant to a negotiated (Hicks-style) plea, Reynolds pleaded guilty to sale of cocaine in an amount of .5 grams or more (Class B felony) and received a 12-year sentence with 60% release eligibility as a career offender.
- The written judgment shows the negotiated plea and contains handwritten and typed notations indicating the plea was made to obtain the 12-year/60% disposition and that a voluntary plea waives irregularities in offender classification/release eligibility.
- Reynolds filed a petition for writ of habeas corpus claiming the indictment was insufficient to support conviction for the increased drug-amount charge and that the judgment was void for lack of jurisdiction; the State moved to summarily dismiss.
- The habeas corpus court granted the State's motion and dismissed the petition without a hearing; Reynolds appealed and the Court of Criminal Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the indictment was insufficient to support plea to a greater drug amount | Reynolds: indictment charged <.5g in school zone; plea was to .5g or more, so he lacked notice and judgment is void | State: plea and judgment show Reynolds consented to the amended charge; error waived/consented and not jurisdictional | Court: Reynolds consented to amendment via plea; indictment deficiency did not render judgment void; dismissal affirmed |
| Whether trial court lacked jurisdiction to enter judgment because of offender classification/release eligibility errors | Reynolds: sentence contravened statutory classifications, so judgment void | State: offender classification and release eligibility issues are non-jurisdictional and waived by a knowing, voluntary plea; sentence within statutory range | Court: classification/release eligibility are non-jurisdictional; plea waived those defects; sentence within Class B range; court had jurisdiction |
| Whether habeas relief was available for these claims | Reynolds: sought habeas to void judgment | State: habeas is limited to void (not voidable) judgments and petition failed to show voidness | Court: petition failed to show facial voidness; summary dismissal appropriate |
| Whether the negotiated plea produced an improper "hybrid" sentence beyond permissible limits | Reynolds: plea altered elements and exposure improperly | State: plea bargaining may mix range/term/release so long as term is within statutory range and release eligibility not below minimum | Court: plea produced a permissible negotiated sentence within statutory outer limits and minimum release eligibility; valid |
Key Cases Cited
- Edwards v. State, 269 S.W.3d 915 (Tenn. 2008) (habeas review is limited and reviewed de novo)
- Potts v. State, 833 S.W.2d 60 (Tenn. 1992) (habeas corpus contests void, not merely voidable, judgments)
- Archer v. State, 851 S.W.2d 157 (Tenn. 1993) (habeas relief available only when record shows convicting court lacked jurisdiction or confinement expired)
- Davis v. State, 313 S.W.3d 751 (Tenn. 2010) (plea bargains may create hybrid sentences so long as term is within statutory range and release eligibility is not below minimum)
- Hoover v. State, 215 S.W.3d 776 (Tenn. 2007) (offender classification and release eligibility are non-jurisdictional and waived by a knowing, voluntary plea)
- Hicks v. State, 945 S.W.2d 706 (Tenn. 1997) (a knowing and voluntary guilty plea waives irregularities in offender classification or release eligibility)