mere clerical error (Tennessee) · Go Syfert
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mere clerical error in Tennessee

5 Tennessee opinions name it 3 courts 1925–2022 1 in the last five years

The cases below were cited by Tennessee courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Douglas Lauren Marsh v. Larry F. Taylor, Wardengreen
ca9 · 1991 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Atkinson v. Bob Guzik, U.S. Parole Comm’n, No. 95-5261, 1995 WL 499502, at *2 (6th Cir. Aug. 21, 1995) (“A mere clerical error or misuse of semantics in a Commission document does not preclude the Commission’s proper application of its regulations and the applicable statutes.” (citing Marsh v. Taylor, 925 F.2d 1131, 1133 (9th Cir. 1991) (per curiam))); Squire v. Fulwood, 75 F. Supp. 3d 548, 550 (D.D.C. 2014) (“[A] typographical error in the document memorializing the jurisdiction of conviction does not change that fact.”); Darrell Joseph Jackson, Jr., v. U.S. Parole Comm’n, No. 13- 4 The July

11
Squire v. Fulwoodgreen
dcd · 2014 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Atkinson v. Bob Guzik, U.S. Parole Comm’n, No. 95-5261, 1995 WL 499502, at *2 (6th Cir. Aug. 21, 1995) (“A mere clerical error or misuse of semantics in a Commission document does not preclude the Commission’s proper application of its regulations and the applicable statutes.” (citing Marsh v. Taylor, 925 F.2d 1131, 1133 (9th Cir. 1991) (per curiam))); Squire v. Fulwood, 75 F. Supp. 3d 548, 550 (D.D.C. 2014) (“[A] typographical error in the document memorializing the jurisdiction of conviction does not change that fact.”); Darrell Joseph Jackson, Jr., v. U.S. Parole Comm’n, No. 13- 4 The July

11
Claude H. Atkinson v. Bob Guzik United States Parole Commissiongreen
ca6 · 1995 · cited in 1 Tennessee opinions naming this issue, 2016–2016
1 sentence

2016Atkinson v. Bob Guzik, U.S. Parole Comm’n, No. 95-5261, 1995 WL 499502, at *2 (6th Cir. Aug. 21, 1995) (“A mere clerical error or misuse of semantics in a Commission document does not preclude the Commission’s proper application of its regulations and the applicable statutes.” (citing Marsh v. Taylor, 925 F.2d 1131, 1133 (9th Cir. 1991) (per curiam))); Squire v. Fulwood, 75 F. Supp. 3d 548, 550 (D.D.C. 2014) (“[A] typographical error in the document memorializing the jurisdiction of conviction does not change that fact.”); Darrell Joseph Jackson, Jr., v. U.S. Parole Comm’n, No. 13- 4 The July

11
Coleman v. Morgangreen
tenncrimapp · 2004 · cited in 1 Tennessee opinions naming this issue, 2010–2010
1 sentence

2010This Court has previously held that an illegal sentence may serve as a basis for habeas relief only if the illegality of the sentence is “egregious to the point of voidness.” Coleman v. Morgan, 159 S.W.3d 887, 890 (Tenn. Crim.

11
State v. Stephensongreen
tenn · 1988 · cited in 1 Tennessee opinions naming this issue, 2003–2003
1 sentence

2003See, e.g., State v. Stephenson, 752 S.W.2d 80, 81 (Tenn.1988) (finding that notice filed the day trial began was not ineffective because the defendant failed to show prejudice or request a continuance); State v. Debro, 787 S.W.2d 932, 933-34 (Tenn.Crim.App.1989) (finding that the notice was not ineffective despite a technical error therein because the defect was a mere clerical error of which the defendant had knowledge).

11
State v. Debrogreen
tenncrimapp · 1989 · cited in 1 Tennessee opinions naming this issue, 2003–2003
1 sentence

2003See, e.g., State v. Stephenson, 752 S.W.2d 80, 81 (Tenn.1988) (finding that notice filed the day trial began was not ineffective because the defendant failed to show prejudice or request a continuance); State v. Debro, 787 S.W.2d 932, 933-34 (Tenn.Crim.App.1989) (finding that the notice was not ineffective despite a technical error therein because the defect was a mere clerical error of which the defendant had knowledge).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Jennifer Parks v. Rebecca A. Walker, M.D. green
tennctapp · 2018
1 sentence

2022The defendants cited Parks v. Walker, 585 S.W.3d 895 , 897-99 (Tenn. Ct. App. 2018), in which this Court concluded that authorizations sent to each defendant authorizing it “to release, use or disclose” the plaintiff’s health records to the other providers were “not sufficient to enable defendants to obtain plaintiff’s medical records.” The defendants also pointed out that Plaintiff had not pled “extraordinary cause” in response to their motions to dismiss, but in the event that Plaintiff raised the argument, they suggested that an envelope stuffing error was a mere clerical error that would n

12022–2022
Sheafer v. Mitchell green
tenn · 1902
1 sentence

1925Sheafer v. Mitchell, 109 Tenn., 181 . *519 The incongruity of dates in the second deed might render it defective, although the date, 1864, might be a mere clerical error.

11925–1925

Where else courts name it

NY 34 (1830–2025) TX 24 (1872–2024) MO 20 (1882–2025) CA 19 (1913–2026) AL 16 (1876–2016) NC 12 (1896–2025) OK 11 (1910–1978) PA 10 (1893–2025) MS 10 (1931–2024) LA 9 (1825–2016) IL 9 (1897–2025) GA 9 (1913–2026) AR 7 (1920–2025) VA 6 (1868–1872) OR 6 (1902–1959) MN 6 (1887–1996) TN 5 (1925–2022) SC 5 (1910–2002) IN 4 (1862–1970) WA 4 (1920–2025) KS 4 (1902–2024) WI 4 (1889–2014) FL 4 (1931–1997) MT 4 (1909–1997) OH 4 (2013–2025) MA 4 (1892–2003) WY 3 (1933–1937) IA 3 (1892–2012) NV 3 (1878–1937) SD 3 (1919–1927) NE 3 (1896–1916) MI 2 (1931–1952) KY 2 (2024–2024) CT 2 (1963–2017) ID 2 (1916–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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