State of Tennessee v. Brandi Michelli Adams

CourtCourt of Criminal Appeals of Tennessee
DecidedJuly 8, 2025
DocketM2024-00723-CCA-R3-CD
StatusPublished

This text of State of Tennessee v. Brandi Michelli Adams (State of Tennessee v. Brandi Michelli Adams) 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
State of Tennessee v. Brandi Michelli Adams, (Tenn. Ct. App. 2025).

Opinion

07/08/2025 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT NASHVILLE Assigned on Briefs June 17, 2025 at Knoxville

STATE OF TENNESSEE v. BRANDI MICHELLI ADAMS

Appeal from the Criminal Court for Fentress County No. 14150 Zachary R. Walden, Judge ___________________________________

No. M2024-00723-CCA-R3-CD ___________________________________

The Defendant, Brandi Michelle Adams,1 pled guilty to the offense of second degree murder as a Range II, multiple offender and received a sentence of forty years. She later filed a motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1, arguing that she was a Range I, standard offender and did not agree to be sentenced in an enhanced range. Following a hearing, the trial court denied the motion, and the Defendant appealed, asserting three issues: (1) that she could not legally be sentenced as a Range II, multiple offender; (2) that her plea was involuntary; and (3) that the trial court exhibited bias in denying her Rule 36.1 motion. Upon our review, we respectfully affirm the judgment of the trial court.

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

TOM GREENHOLTZ, J., delivered the opinion of the court, in which CAMILLE R. MCMULLEN, P.J., and ROBERT H. MONTGOMERY, JR., J., joined.

Brandi Michelle Adams, Nashville, Tennessee, Pro Se.

Jonathan Skrmetti, Attorney General and Reporter; William C. Lundy, Assistant Attorney General; Jared R. Effler, District Attorney General; and Danielle Montooth and Philip A. Kazee, Assistant District Attorneys General, for the appellee, State of Tennessee.

1 The original indictment and judgment spell the Defendant’s name as “Brandi Michelli Adams.” This spelling appears to be a typographical error, as the record reflects that both the trial court and the Defendant have consistently used the spelling “Brandi Michelle Adams.” We retain the spelling from the indictment for use in the case caption, consistent with our usual practice. Otherwise, we use the Defendant’s preferred spelling in the opinion itself. OPINION

FACTUAL BACKGROUND

On December 2, 2014, a Fentress County grand jury indicted the Defendant for first degree felony murder. She later pled guilty to a reduced charge of second degree murder as a Range II, multiple offender. Pursuant to the terms of the plea agreement, the Defendant accepted a forty-year sentence in the Department of Correction with no release eligibility.

In October 2023, the Defendant filed a pro se motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1. More specifically, she alleged that her sentence was illegal because she was properly classified as a Range I, standard offender and did not waive her range classification for sentencing purposes.

The trial court summarily denied this motion through entry of a written order in December 2023. The court concluded that the Defendant’s sentence was within the statutory range for a Class A felony offense and that the claim was contradicted by her signed plea agreement and the transcript from her plea hearing. The Defendant did not seek an appeal from this denial.

In April 2024, the Defendant filed a renewed Rule 36.1 motion, raising the same issues previously asserted.2 The trial court conducted a hearing, during which it reviewed the original plea agreement with the Defendant, including the provisions related to Range II sentencing, and discussed her concerns. Following the hearing, the court denied the motion for the same reasons set forth in its earlier order and subsequently entered a written ruling memorializing its decision on August 23, 2024.

2 We have consistently recognized that Rule 36.1 “may not be used to relitigate those issues that have been previously determined,” including claims resolved in an earlier Rule 36.1 proceeding. See State v. McDougle, No. W2022-01103-CCA-R3-CD, 2023 WL 2968224, at *3 (Tenn. Crim. App. Apr. 17, 2023), perm. app. denied (Tenn. June 28, 2023). In this case, the Defendant explains that she renewed her request because she did not receive a copy of the trial court’s prior order denying her initial motion. Perhaps for that reason, the trial court did not summarily dismiss the renewed motion—as it was authorized to do— but instead held a hearing. At that hearing, the court addressed the matter in person with the Defendant and, in its order denying relief, considered information from both the hearing and the earlier petition. Under these circumstances, we elect to consider the merits of the Defendant’s claim.

2 Before the hearing, the Defendant filed a premature notice of appeal. This notice of appeal became effective upon entry of the trial court’s order. See Tenn. R. App. P. 4(d).

STANDARD OF APPELLATE REVIEW

With respect to every issue on appeal, our supreme court has recognized that a reviewing court must ask, “[W]hat is the appropriate standard of review?” State v. Enix, 653 S.W.3d 692, 698 (Tenn. 2022). The principal issue in this case is whether the trial court properly found that the Defendant failed to state a colorable claim for relief pursuant to Tennessee Rule of Criminal Procedure 36.1. This question is one of law that we review de novo on appeal. See State v. Wooden, 478 S.W.3d 585, 589 (Tenn. 2015); State v. Pettie, No. M2024-00558-CCA-R3-CD, 2024 WL 5075376, at *2 (Tenn. Crim. App. Dec. 11, 2024), no perm. app. filed.

ANALYSIS

The Defendant raises three arguments in this appeal. First, she contends that her forty-year sentence is illegal because she was a Range I, standard offender and did not agree to be sentenced as a Range II, multiple offender. Next, she asserts that her guilty plea was not knowing or voluntary because she did not understand that she was waiving her offender classification. Finally, she claims that the trial court exhibited bias in denying her Rule 36.1 motion.

In response, the State maintains that the sentence is lawful because it falls within the statutory range for a Class A felony. It further argues that any challenge to the voluntariness of the plea is not cognizable under Rule 36.1 and is, in any event, contradicted by the record. Finally, the State contends that the Defendant’s allegation of judicial bias is waived for failure to provide supporting argument or citations to the appellate record. We agree with the State.

Tennessee Rule of Criminal Procedure 36.1 provides that a defendant “may seek to correct an illegal sentence by filing a motion . . . in the trial court in which the judgment of conviction was entered.” Tenn. R. Crim. P. 36.1(a)(1). An illegal sentence is “one that is not authorized by the applicable statutes or that directly contravenes an applicable statute.” Tenn. R. Crim. P. 36.1(a)(2). If the trial court “determines that the motion fails to state a colorable claim, it shall enter an order summarily denying the motion.” Tenn. R. Crim. P. 36.1(b)(2). A “colorable claim” means “a claim that, if taken as true and viewed

3 in a light most favorable to the moving party, would entitle the moving party to relief under Rule 36.1.” Wooden, 478 S.W.3d at 585, 593.

Our supreme court has also observed that “few sentencing errors render sentences illegal.” See id. at 595. Sentencing errors may be clerical, appealable, or fatal, but “only fatal errors render sentences illegal.” State v. Reid, 620 S.W.3d 685, 689 (Tenn. 2021) (citation and internal quotation marks omitted).

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David CANTRELL v. Joe EASTERLING, Warden
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478 S.W.3d 585 (Tennessee Supreme Court, 2015)

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Bluebook (online)
State of Tennessee v. Brandi Michelli Adams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-tennessee-v-brandi-michelli-adams-tenncrimapp-2025.