fatal error (Tennessee) · Go Syfert
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fatal error in Tennessee

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.

Followed or applied (3)

CaseFollowedCited
State of Tennessee v. James D. Woodengreen
tenn · 2015 · cited in 12 Tennessee opinions naming this issue, 2017–2026
2 sentences

2024Whether 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).

212
State of Tennessee v. Adrian R. Browngreen
tenn · 2015 · cited in 2 Tennessee opinions naming this issue, 2017–2025
2 sentences

2025See 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).

22
Summers v. Stategreen
tenn · 2007 · cited in 1 Tennessee opinions naming this issue, 2024–2024
1 sentence

2024Whether 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.

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 (5)

CaseCitedYears
David CANTRELL v. Joe EASTERLING, Warden green
tenn · 2011
1 sentence

2025Rule 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.

12025–2025
State v. Burkhart green
tenn · 1978
1 sentence

2017On 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.

12017–2017
Moody v. State green
tenn · 2005
1 sentence

2017On 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.

12017–2017
Stilwell v. Carpenter green
ny · 1875
1 sentence

1944Stilwell v. Carpenter, 62 N. Y. 639 , 2 Abb.

11944–1944
Stilwell v. . Carpenter green
ny · 1875
1 sentence

1944Stilwell v. Carpenter, 62 N. Y. 639 , 2 Abb.

11944–1944

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 40-35-112 (4) TN § Tenn. Code Ann. § 39-13-524 (3) TN § Tenn. Code Ann. § 40-35-115 (3)

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.

Where else courts name it

PA 85 (1896–2025) CA 29 (1892–2024) MS 21 (1911–2018) TX 20 (1873–2026) OH 17 (1988–2024) LA 17 (1903–2024) NC 17 (1896–2019) TN 16 (1944–2026) NY 15 (1848–2014) AL 12 (1849–2012) IL 12 (1884–2025) NJ 10 (2005–2026) WA 10 (1918–2020) KS 10 (1872–2024) MO 9 (1882–1993) IN 8 (1881–1989) WV 8 (1883–2009) FL 8 (1981–2022) CO 7 (1875–2007) NE 7 (1909–1999) ID 6 (1923–2026) MI 6 (1856–2024) GA 6 (2010–2022) AR 6 (1935–2003) IA 5 (1883–2025) KY 5 (1974–2018) WI 5 (1849–2023) UT 4 (1986–2025) OK 3 (1943–1989) PR 3 (1941–1970) VT 3 (1978–2013) CT 3 (2003–2019) MD 2 (2008–2012) MA 2 (1939–1985) NM 2 (1926–1957) AZ 2 (1978–2006) DE 2 (2017–2025)

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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