Isaih Tatum v. State of Tennessee

CourtCourt of Criminal Appeals of Tennessee
DecidedMarch 24, 2025
DocketE2024-01196-CCA-R3-PC
StatusPublished

This text of Isaih Tatum v. State of Tennessee (Isaih Tatum v. State of Tennessee) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Isaih Tatum v. State of Tennessee, (Tenn. Ct. App. 2025).

Opinion

03/24/2025 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT KNOXVILLE Assigned on Briefs March 18, 2025

ISAIH TATUM v. STATE OF TENNESSEE

Appeal from the Criminal Court for McMinn County No. 23-CR-151 Sandra N. C. Donaghy, Judge ___________________________________

No. E2024-01196-CCA-R3-PC ___________________________________

Petitioner, Isaih Tatum, pleaded guilty to possession of more than 0.5 grams of methamphetamine with intent to sell or deliver and unlawful possession of a weapon by a convicted felon and received an agreed sentence of ten years. He subsequently filed a petition for post-conviction relief, which the McMinn County Criminal Court denied after a hearing. On appeal, Petitioner contends that the post-conviction court erred when it denied relief on his claims that he was denied the effective assistance of counsel and that his guilty plea was not knowingly and voluntarily entered. Following a thorough review, we affirm.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Criminal Court Affirmed

ROBERT L. HOLLOWAY, JR., J., delivered the opinion of the court, in which ROBERT H. MONTGOMERY, JR., and JILL BARTEE AYERS, JJ., joined.

Andrew E. Bateman, Athens, Tennessee, for the appellant, Isaih Tatum.

Jonathan Skrmetti, Attorney General and Reporter; Abigail H. Hornsby, Assistant Attorney General; Stephen Hatchett, District Attorney General; and Matthew Walden, Assistant District Attorney General, for the appellee, State of Tennessee.

OPINION

Factual and Procedural Background

Following a traffic stop on December 4, 2022, Petitioner was arrested and charged with possession of more than 0.5 grams of methamphetamine with intent to sell or deliver, possession of drug paraphernalia, and unlawful possession of a weapon by a convicted felon. The charges were brought to criminal court for a plea by information through an agreement negotiated by the parties in general sessions court.

Plea Submission Hearing

On January 13, 2023, Petitioner pleaded guilty to possession of more than 0.5 grams of methamphetamine with intent to sell or deliver and unlawful possession of a weapon by a convicted felon. During the plea submission hearing, the State offered the following factual basis for Petitioner’s guilty plea:

Your Honor, [on] December 4th, of 2022, a [d]eputy with the McMinn County Sheriff’s Department was watching traffic on Interstate 75, and [Petitioner] was, in a vehicle that passed by this [o]fficer with what appeared to be an illegal window tint. The [o]fficer performed a traffic stop on the vehicle, found that the registration came back to a driver with a revoked license. When he approached the car, he could smell marijuana as the window was being rolled down. He spoke at that time with the driver and then [Petitioner], who was a passenger in the vehicle at the time.

The officer also observed a glass pipe inside the vehicle. [Petitioner] told the [o]fficer that that was his and anything else in the car was his. When the [o]fficer asked if there was anything else in the car, [Petitioner] said that he would just have to search it. Officers conducted a probable cause search of the vehicle and retrieved the pipe along with a .380 pistol, [and] a small bag of methamphetamine under the passenger seat.

In the seat was a toboggan that had two more bags of suspected methamphetamine and also a digital scale. Bag one weighed approximately three grams, bag two weighed approximately three grams, and then the final bag weighed approximately 21 grams.

Behind the passenger seat, officers also found a 9mm semi-automatic rifle.

When [Petitioner] was placed under arrest, officers also found another set of digital scales in [Petitioner’s] pocket.

[Petitioner] is a convicted felon out of the State of Tennessee for a prior robbery conviction.

-2- Before accepting Petitioner’s guilty plea, the trial court reviewed the plea paperwork with Petitioner. The court stated:

On count one, it says you have an agreement with the State to plead guilty as charged. The State is recommending on this case that you be sentenced as a [R]ange [I] offender to a period of [ten] years. It says this is a sentence that is to be served.

They have awarded you the jail credits that you have built from December 4 until today.

And it also says they agree this case will be concurrent or at the same time with a sentence you have out of Hamilton County and with count two.

The trial court also discussed Petitioner’s intent to plead guilty to unlawful possession of a weapon by a convicted felon in count two and explained that Petitioner would be sentenced to four years as a Range II offender. When asked by the trial court, Petitioner agreed that he understood what he was accused of and the potential punishments for the charges and that he was waiving his right to have a grand jury review the charges. The court found that Petitioner “freely and voluntarily” waived his right to grand jury review and accepted the court’s jurisdiction over the case.

The trial court then reviewed Petitioner’s constitutional rights, explaining:

[T]he Constitution guarantees you the right to a speedy and public trial by jury. At a jury trial, the State would have to prove by evidence beyond a reasonable doubt that you committed the elements of the crimes charged.

You would have the right to confront the witnesses against you, and those persons could be cross[-]examined on your behalf by your attorney.

You have the right to use the power in the process of the [c]ourt to make the State show you the evidence to be used against you or to make your witnesses come to a jury trial.

At a jury trial, you could testify if you chose to do so. You have the right to remain silent, and no one can make you testify.

You also have the right to be represented by an attorney, and that right attaches at all stages of the proceeding.

-3- Petitioner indicated that he understood his constitutional rights, and he agreed that, by pleading guilty, he was waiving those rights.

Petitioner stated that he was not under the influence of drugs or alcohol. When asked by the court about his mental health, Petitioner said that he had been treated for mental health problems previously but indicated that those problems did not prevent him from understanding “what’s going on here[.]” Petitioner stated that he had had no problems communicating with trial counsel. When questioned by the trial court, trial counsel stated that he had no concerns about whether Petitioner was competent to plead guilty. Trial counsel stated, “[Petitioner] and I have had no problems communicating. He’s wanted to take this offer since we got it. He’s been able to discuss the case with me and his criminal history, his exposure, everything else.”

Following this colloquy, the trial court told Petitioner:

You asked me some good questions, and as I answered those questions for you, it was clear to me that we were communicating about your case. And so, in spite of those problems you’ve been having, based on all of that information, I make a finding that you know and understand what you’re doing, and I find that you are legally competent to make big decisions like giving up your constitutional rights.

Petitioner agreed that he signed the plea paperwork, that the resolution of the charges was in his best interests, and that he was pleading guilty because he was guilty. The trial court accepted Petitioner’s guilty plea, finding that Petitioner understood what he was doing and that he was “freely and voluntarily” giving up his rights to enter the plea agreement. Pursuant to the agreement, the trial court sentenced Petitioner, as a Range I offender, to ten years for possession of more than 0.5 grams of methamphetamine with intent to sell or deliver.

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State v. Turner
919 S.W.2d 346 (Court of Criminal Appeals of Tennessee, 1995)
Howell v. State
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Blankenship v. State
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Baxter v. Rose
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Finch v. State
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State v. MacKey
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Edward Thomas Kendrick, III v. State of Tennessee
454 S.W.3d 450 (Tennessee Supreme Court, 2015)

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Bluebook (online)
Isaih Tatum v. State of Tennessee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/isaih-tatum-v-state-of-tennessee-tenncrimapp-2025.