State v. Robert McKnight

CourtCourt of Criminal Appeals of Tennessee
DecidedDecember 1, 2010
Docket02C01-9810-CC-00310
StatusPublished

This text of State v. Robert McKnight (State v. Robert McKnight) 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 v. Robert McKnight, (Tenn. Ct. App. 2010).

Opinion

IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE

AT JACKSON

JUNE SESSION, 1999 FILED August 5, 1999 STATE OF TENNESSEE, ) C.C.A. NO. 02C01-9810-CC-00310 Cecil Crowson, Jr. ) Appellate Court Clerk Appellee, ) ) ) MADISON COUNTY VS. ) ) HON. ROY B. MORGAN, JR. ROBERT M. McKNIGHT, ) JUDGE ) Appe llant. ) (Habeas Corpus)

ON APPEAL FROM THE JUDGMENT OF THE CIRCUIT COURT OF MADISON COUNTY

FOR THE APPELLANT: FOR THE APPELLEE:

C. MARK DONAHOE PAUL G. SUMMERS 312 East Lafayette Street Attorney General and Reporter P.O. Box 2004 Jackson, TN 38302-2004 PATRICIA C. KUSSMANN Assistant Attorney General 425 Fifth Avenu e North Nashville, TN 37243

JERRY W OODALL District Attorney General

SHAUN A. BROWN Assistant District Attorney General P.O. Box 2825 Jackson, TN 38302

OPINION FILED ________________________

AFFIRMED

DAVID H. WELLES, JUDGE OPINION

In this appeal we determine whether the Defendant’s sentences for two

DUI conviction s expired during the time the s heriff could not incarcerate the

Defendant due to an overcr owde d jail. Th e trial co urt ruled that the Defe ndan t’s

sentences had not expired. We agree and affirm the judgment of the trial court.

On May 7, 1997, the Defendant pleaded guilty to and was convicted of

DUI, second offense and DUI, third offense.1 For these convictions, he received

consecu tive senten ces of ele ven mo nths an d twenty-n ine days in the cou nty

workhouse. He was ordered to serve 150 days in confinement for one of the

convictions, followed by sixty days co nfinem ent for the o ther con viction, with the

balance of his sente nces to be s erved on pro bation . His effective sentence was

thus two years, with 2 10 days to be serv ed in con fineme nt. 2

The Defendant imm ediate ly presented himself to the county sheriff’s office

to begin serving his sentences. He was told that no spac e was availab le for him

to serve his sentences and that he would be notified when to report. In August

of 1998, the Defen dant rec eived no tice from th e sheriff’s off ice that he w as to

report to begin serving his effective 210-day sentence.

On September 3, 1998, the Defendant filed a “Motion for Post-Conviction

Relief and/or W rit of Habe as Cor pus.” He asserted that the notification to report

1 Tenn. Code Ann. §§ 55-10-401, -403. 2 The Defendant was also convicted of and sentenced for other offenses, none of which is relevant to the issues presented in this appeal.

-2- to jail came over one year after his sentences became final and stated tha t “[t]o

require the Defendant to serve a sentence after expiration of the sentence is a

violation of the Defendant’s due process rights, violation of the credit for time at

liberty doctrin e and is a violation of the principle o f fundam ental fairne ss.”

The trial court conducted a hearing on the Defendant’s motion, at which

time the pa rties stip ulated to the p ertinent facts as stated herein. At the

conclusion of the hearing, the trial cou rt denied the D efendant re lief from h is

sentences, relying on th e provisions of Tennessee Code Annotated § 55-10-

403(p)(3). From this order, the Defendant now appeals.

In this appeal, the Defendant relies primarily on State v. Walker, 905

S.W.2d 554 (T enn. 1995). The facts presented in Walker were qu ite similar to

those presented in the case at b ar. On August 27, 1990, Defendant Walker was

convicted of DUI and received a jail sentence of eleven months and twenty-nine

days, with all but twen ty days su spend ed. Id. at 555 . He re ported to the s heriff’s

office to begin serving his sentence and was told that no space was available and

that he would b e notified w hen to re port. Id. Almost two years later he received

the notice to re port to jail. Id. He sought relief from his sentence, alleging that

it had exp ired. Id. The trial court denied Walker relief and this Court affirmed,

however, our supreme court granted Walker re lief. Id. The C ourt bas ed its

decision upon a n interpre tation of our statutes, holding that “where persons under

a crimina l sente nce im med iately pr esen t them selves to the a pprop riate

authorities for incarc eration and a re turn ed aw ay the s enten ce in each case shall

begin to run when the judgment of conviction becomes final or the prisoner is

actually incarcerated , whichever is earlier.” Id. at 557.

-3- In Walker, our supreme court first discussed the due process and

fundamental fairness concerns, including the “cred it for time at liberty” doctrine:

The effect of an inordinate delay in the execution of a criminal judgment has been frequently litigated in other courts. Even w here the delay results from simple negligence or oversight, the courts have recognized that relief from the sentence might be ava ilable on due process grounds. In [these] cases the courts also analyzed the claims on the basis of waiver or estoppel but refused relief on any basis because of the high standard that must be met before relief is available. (The State’s action “must b e so affirm atively wron g or its inaction so grossly negligent that it would be un equivo cally inconsistent with ‘fundamental principles of libe rty and justic e’ to require a legal sentence to be served in the aftermath of such action of inaction.”) Another doctrine called “cred it for time at liberty” has been invoked where the de fendant has been incarce rated unde r a criminal judgmen t but erroneou sly released thro ugh no fault of h is own. Unde r those circ umsta nces the courts hold that his sentence continues to run wh ile he is at liberty. We know of no instance, however, where this doctrine has been applied to a situation w here no time at all has been served. In other cases, most of them in the state courts, where the defendant has presented himself for incarceration and has been refused admission for some reason (an overcr owde d jail or s imple inaction on the part of the jailer) the courts have said that the sentence began to run w hen th e defe ndan t did all that was required of him to allow the imposition of the criminal sentence. The lack of in depth analysis in some of the state case s—p articula rly the part played by state statutes—persuades us that there is no uniform constitutional standard that has been applied in cases where a defe ndan t is refus ed ad miss ion to th e jail because of overcrowded conditions. We cannot say that under those conditions the State’s action is so affirmatively wrong or gross ly neglig ent tha t further incarc eration would be inconsistent with fundamental principles of liberty and justice. We will, therefore, exam ine the qu estion ba sed on our own statutes.

Id. at 555-56 (citations o mitted).

In the case at bar, as in Walker, we cannot conclude that service of the

Defe ndan t’s senten ces wo uld violate his due process rights or otherwise offend

principles of fundam ental fairness. He re, the Defend ant received an effective

sentence of two years. Due to overcrowded jail conditions, space was not

availab le to acc omm odate incarceration of the D efendant for ap proximately a

-4- year after he was sentenced. Any inconvenience to the Defendant is certainly not

sufficient to violate D efenda nt’s due p rocess rights. Under these conditions and

circumstances, we ca nnot c onclu de tha t the Sta te’s ac tion is so affirma tively

wrong or gross ly negligen t that incarc eration w ould be inconsis tent with

fundamental principles of liberty and justice.

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Related

State v. Walker
905 S.W.2d 554 (Tennessee Supreme Court, 1995)

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Bluebook (online)
State v. Robert McKnight, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-robert-mcknight-tenncrimapp-2010.