State of Tennessee v. Koalis Peete

CourtCourt of Criminal Appeals of Tennessee
DecidedAugust 21, 2025
DocketW2024-01211-CCA-R3-CD
StatusPublished

This text of State of Tennessee v. Koalis Peete (State of Tennessee v. Koalis Peete) 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. Koalis Peete, (Tenn. Ct. App. 2025).

Opinion

08/21/2025 IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE AT JACKSON Assigned on Briefs August 5, 2025

STATE OF TENNESSEE v. KOALIS PEETE

Appeal from the Criminal Court for Shelby County Nos. 16-05602, 16-04956, 16-04955 Chris Craft, Judge ___________________________________

No. W2024-01211-CCA-R3-CD ___________________________________

The Defendant, Koalis Peete, appeals the trial court’s summary dismissal of his motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1. Discerning no error, we affirm.

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

STEVEN W. SWORD, J., delivered the opinion of the court, in which CAMILLE R. MCMULLEN and KYLE A. HIXSON, JJ., joined.

Koalis Peete, Hartsville, Tennessee, Pro Se.

Jonathan Skrmetti, Attorney General and Reporter; Johnny Cerisano, Assistant Attorney General; Steven J. Mulroy, District Attorney General; and Leslie Byrd, Assistant District Attorney General, for the appellee, State of Tennessee.

OPINION

I. FACTUAL AND PROCEDURAL HISTORY

On December 18, 2020, the Defendant pled guilty to second degree murder, aggravated robbery, and attempted aggravated robbery, pursuant to a negotiated plea agreement.1 The trial court imposed sentences of thirty-five years’ incarceration for the second degree murder conviction, twelve years’ incarceration for the aggravated robbery

1 As discussed below, the appellate record does not include copies of the indictment, plea agreement, or judgment forms. However, the trial court and the parties on appeal agree as to the nature of the Defendant’s convictions. conviction, and six years’ incarceration for the attempted aggravated robbery conviction.2 Each sentence was aligned concurrently, yielding a total effective sentence of thirty-five years’ incarceration.

On June 21, 2024, the Defendant filed a motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1. In his motion, the Defendant alleged his sentence was illegal because his “plea was based on fraud.” Specifically, he asserted the State made knowing misrepresentations during plea negotiations by recommending the Defendant be sentenced as a Range II, multiple offender, because the Defendant’s prior criminal record did not justify such a classification. The Defendant argued he should have been sentenced as a Range I, standard offender, and as such, his sentences of thirty-five years’ incarceration for second degree murder and twelve years’ incarceration for aggravated robbery exceeded the appropriate sentencing range.

On July 8, 2024, the trial court entered an order summarily denying the Defendant’s Rule 36.1 motion. In its order, the trial court concluded the Defendant “bargained for and agreed to receive” his sentences and consented to his classification as a Range II, multiple offender, “rather than face a possible sentence of life imprisonment for” first degree murder, as charged in his indictment. The trial court further concluded that each of the Defendant’s sentences was within the applicable sentencing range for a Range II, multiple offender. The Defendant, proceeding pro se, filed a timely notice of appeal by delivering the notice to the appropriate individual at the correctional facility in which he was incarcerated on July 31, 2024.3

II. ANALYSIS

2 In his trial court motion, the Defendant contended he received a thirty-three-year sentence. He does not reiterate this contention in his appellate brief; in fact, his appellate brief makes no mention of the specific length of the sentence for which he seeks correction. 3 In its appellate brief, the State contends the Defendant’s notice of appeal was untimely filed on August 13, 2024, the date it was file-stamped by the appellate court clerk. Tennessee Rule of Appellate Procedure 4(a) requires that an appealing party file a notice of appeal “with the clerk of the appellate court within 30 days after the date of entry of the judgment appealed from[.]” However,

[i]f papers required or permitted to be filed pursuant to the rules of appellate procedure are prepared by or on behalf of a pro se litigant incarcerated in a correctional facility and are not received by the clerk of the court until after the time fixed for filing, filing shall be timely if the papers were delivered to the appropriate individual at the correctional facility within the time fixed for filing.

Tenn. R. App. P. 20(g). The envelope in which the Defendant’s notice of appeal was mailed from the correctional facility contains a postmark indicating it was mailed on July 31, 2024. The Defendant’s notice of appeal was, therefore, timely. -2- On appeal, the Defendant argues the trial court erred by summarily dismissing his Rule 36.1 motion, reiterating that his sentence is illegal because he “entered into a plea agreement that included as a material element a recommendation for an out-of-range sentence.” He maintains that his prior criminal record did not justify his classification as a Range II, multiple offender; that he should have been classified as a Range I, standard offender; and that, accordingly, the sentences he received exceeded the applicable range. The State responds, and we agree, that summary dismissal was appropriate.

Tennessee Rule of Criminal Procedure 36.1 provides both the criminal defendant and the State an avenue to seek the correction of an illegal sentence at any time before the sentence has expired. “[A]n 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); State v. Wooden, 478 S.W.3d 585, 594 (Tenn. 2015). A motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1 “must state with particularity the factual allegations on which the claim for relief from an illegal sentence is based.” Wooden, 478 S.W.3d at 594. “If the motion states a colorable claim that the unexpired sentence is illegal, . . . and if the defendant is indigent and is not already represented by counsel, the court shall appoint counsel to represent the defendant.” Tenn. R. Crim. P. 36.1(b)(3). On the other hand, if the trial court, after reviewing the motion, any response thereto, and the record, “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 is “a claim that, if taken as true and viewed 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 593. Whether a motion to correct an illegal sentence pursuant to Tennessee Rule of Criminal Procedure 36.1 states a colorable claim for relief is a question of law which this court reviews de novo. Id. at 589 (citing Summers v. State, 212 S.W.3d 251, 255 (Tenn. 2007)).

As relevant to this appeal, Rule 36.1 requires a defendant seeking the correction of an allegedly illegal sentence to “attach to the motion a copy of each judgment order at issue.” Tenn. R. Crim. P. 36.1(a)(1). The Defendant references this requirement in both his trial court motion and in his appellate brief; however, it is unclear whether he attached copies of his judgments of conviction to his Rule 36.1 motion.

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Related

David CANTRELL v. Joe EASTERLING, Warden
346 S.W.3d 445 (Tennessee Supreme Court, 2011)
Summers v. State
212 S.W.3d 251 (Tennessee Supreme Court, 2007)
State v. Oody
823 S.W.2d 554 (Court of Criminal Appeals of Tennessee, 1991)
State of Tennessee v. James D. Wooden
478 S.W.3d 585 (Tennessee Supreme Court, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
State of Tennessee v. Koalis Peete, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-tennessee-v-koalis-peete-tenncrimapp-2025.