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16 Tennessee opinions name it 2 courts 1944–2026 7 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.
| Case | Followed | Cited |
|---|---|---|
State of Tennessee v. James D. Woodengreen2 sentences2024Whether a “[Rule 36.1] motion states a colorable claim for correction of an illegal sentence under Rule 36.1 is a question of law, to which de novo review applies.” Id. at 589 (citing Summers v. State, 212 S.W.3d 251, 255 (Tenn. 2007)). -5- The trial court properly denied Petitioner relief because his sentence did not contain a fatal error. 2022Unlike a fatal error, a clerical error is one arising “‘from a clerical mistake in filling out the uniform judgment document’ and may be corrected at any time under Tennessee Rule of Criminal Procedure 36.” State v. Wooden, 478 S.W.3d 585, 595 (Tenn. 2015). | 2 | 12 |
State of Tennessee v. Adrian R. Browngreen2 sentences2025See Brown, 479 S.W.3d at 212 (holding that a trial court’s erroneous failure to comply with a statute did not render the defendant’s sentence illegal when it did not alter the sentence in any way). 2017Brown, 479 S.W.3d at 212-13 (determining that pre-trial jail credit claims cannot form the basis for relief under Rule 36.1). | 2 | 2 |
Summers v. Stategreen1 sentence2024Whether a “[Rule 36.1] motion states a colorable claim for correction of an illegal sentence under Rule 36.1 is a question of law, to which de novo review applies.” Id. at 589 (citing Summers v. State, 212 S.W.3d 251, 255 (Tenn. 2007)). -5- The trial court properly denied Petitioner relief because his sentence did not contain a fatal error. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Tennessee. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
David CANTRELL v. Joe EASTERLING, Warden
green
1 sentence2025Rule 36.1 relief.”) (first citing Cantrell, 346 S.W.3d at 454-55 ; and then citing Williams v. State, No. 01C01-9506-Cr-00190, 1996 WL 233982 , at *5 (Tenn. Crim. | 1 | 2025–2025 |
State v. Burkhart
green
1 sentence2017On appeal, the Petitioner argues, “Since [he] was serving Davidson County sentences at the time the Johnson County offense was committed, the Johnson County sentencing [c]ourt did not have jurisdiction to impose the illegal sentence and/or to commit the fatal error.” He references State v. Moody, 160 S.W.3d 512 (Tenn. 2005) and State v. Burkhart, 566 S.W.2d 871 (Tenn. 1978), but does not extrapolate how these cases support his claim. | 1 | 2017–2017 |
Moody v. State
green
1 sentence2017On appeal, the Petitioner argues, “Since [he] was serving Davidson County sentences at the time the Johnson County offense was committed, the Johnson County sentencing [c]ourt did not have jurisdiction to impose the illegal sentence and/or to commit the fatal error.” He references State v. Moody, 160 S.W.3d 512 (Tenn. 2005) and State v. Burkhart, 566 S.W.2d 871 (Tenn. 1978), but does not extrapolate how these cases support his claim. | 1 | 2017–2017 |
Stilwell v. Carpenter
green
1 sentence1944Stilwell v. Carpenter, 62 N. Y. 639 , 2 Abb. | 1 | 1944–1944 |
Stilwell v. . Carpenter
green
1 sentence1944Stilwell v. Carpenter, 62 N. Y. 639 , 2 Abb. | 1 | 1944–1944 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.