Burford rule (Tennessee) · Go Syfert
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Burford rule in Tennessee

65 Tennessee opinions name it 2 courts 1995–2021 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
Sands v. Stategreen
tenn · 1995 · cited in 50 Tennessee opinions naming this issue, 1996–2021
2 sentences

2018Our supreme court described the three steps of the “Burford rule” as follows: “(1) determine when the limitations period would normally have begun to run; (2) determine whether the grounds for relief actually arose after the limitations period would normally have commenced; and (3) if the grounds are ‘later- arising,’ determine if, under the facts of the case, a strict application of the limitations period would effectively deny the petitioner a reasonable opportunity to present the claim.” -5- Id. (quoting Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995)).

2018Our supreme court described the three steps of the “Burford rule” as follows: “(1) determine when the limitations period would normally have begun to run; (2) determine whether the grounds for relief actually arose after the limitations period would normally have commenced; and (3) if the grounds are ‘later- arising,’ determine if, under the facts of the case, a strict application of the limitations period would effectively deny the petitioner a reasonable opportunity to present the claim.” Id. (quoting Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995)).

3250
Ricky HARRIS v. STATE of Tennesseered
tenn · 2010 · cited in 8 Tennessee opinions naming this issue, 2013–2017
2 sentences

2017Our supreme court described the three steps of the ―Burford rule‖ as follows: ―(1) determine when the limitations period would normally have begun to run; (2) determine whether the grounds for relief actually arose after the limitations period would normally have commenced; and (3) if the grounds are ‗later- arising,‘ determine if, under the facts of the case, a strict application of the limitations period would effectively deny the petitioner a reasonable opportunity to present the claim.‖ Id. (quoting Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995)). ―Whether due process considerations requ

2017“Whether due process considerations require tolling of a statute of limitations is a mixed question of law and fact, which we review de novo with no presumption of correctness.” Harris, 301 S.W.3d at 145 .

48
Burford v. Stategreen
tenn · 1992 · cited in 28 Tennessee opinions naming this issue, 1995–2018
2 sentences

2018Our supreme court described the three steps of the “Burford rule” as follows: “(1) determine when the limitations period would normally have begun to run; (2) determine whether the grounds for relief actually arose after the limitations period would normally have commenced; and (3) if the grounds are ‘later- arising,’ determine if, under the facts of the case, a strict application of the limitations period would effectively deny the petitioner a reasonable opportunity to present the claim.” -5- Id. (quoting Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995)).

2018Our supreme court described the three steps of the “Burford rule” as follows: “(1) determine when the limitations period would normally have begun to run; (2) determine whether the grounds for relief actually arose after the limitations period would normally have commenced; and (3) if the grounds are ‘later- arising,’ determine if, under the facts of the case, a strict application of the limitations period would effectively deny the petitioner a reasonable opportunity to present the claim.” Id. (quoting Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995)).

328
Caldwell v. Stategreen
tenn · 1996 · cited in 1 Tennessee opinions naming this issue, 1997–1997
1 sentence

1997See Caldwell v. State, 917 S.W.2d 662 (Tenn. 1996), cert. denied ___ U.S. ___, 117 S.Ct. 148 , 136 L.Ed.2d 94 (1996) and Sands v. State, 903 S.W.2d 297 (Tenn. 1995).

11
Canatella v. Carrgreen
scotus · 1996 · cited in 1 Tennessee opinions naming this issue, 1997–1997
1 sentence

1997See Caldwell v. State, 917 S.W.2d 662 (Tenn. 1996), cert. denied ___ U.S. ___, 117 S.Ct. 148 , 136 L.Ed.2d 94 (1996) and Sands v. State, 903 S.W.2d 297 (Tenn. 1995).

11
Forbes v. Patrissigreen
scotus · 1996 · cited in 1 Tennessee opinions naming this issue, 1997–1997
1 sentence

1997See Caldwell v. State, 917 S.W.2d 662 (Tenn. 1996), cert. denied ___ U.S. ___, 117 S.Ct. 148 , 136 L.Ed.2d 94 (1996) and Sands v. State, 903 S.W.2d 297 (Tenn. 1995).

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 (4)

CaseCitedYears
Tommy Nunley v. State of Tennessee green
· 2018
2 sentences

2021Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995), overruled on other grounds by Nunley, 552 S.W.3d 800 .

2021Sands v. State, 903 S.W.2d 297, 301 (Tenn. 1995), overruled on other grounds by Nunley, 552 S.W.3d 800 .

22020–2021
Williams v. State green
tenn · 2001
2 sentences

2020Sands v. State, 903 S.W.2d 297, 300 (Tenn. 1995). -3- Relying on Williams, the petitioner claims coram nobis counsel’s alleged misrepresentation constitutes a violation of due process which should toll the statute of limitations. 44 S.W.3d 464 .

2011The Tennessee Supreme Court applied the Burford principle in Williams v. State, 44 S.W.3d 464 (Tenn. 2001).

22011–2020
Wooden v. State green
tenncrimapp · 1994
2 sentences

1999E.g., Wooden v. State, 898 S.W.2d 752 (Tenn.Crim.App.1994) (remanded for hearing to determine whether evidence was exculpatory and if so, whether Burford exception applied); Sample v. State, No. 02C01-9505-CR-00131 and No. 02C01-9505-CR-00139, 1996 WL 551754 (Tenn.Crim.App., Jackson, Sept. 30, 1996) (applying Burford exception and remanding for further proceedings on exculpatory evidence); Armstrong v. State, No. 01C01-9311-CR-00403, 1994 WL 695424 (Tenn.Crim.App., Nashville, Dec. 8, 1994) (applying Burford exception and remanding for proceedings on exculpatory evidence issue).

1998Wooden v. State, 898 S.W.2d 752 (Tenn. Crim.

21998–1999
Pervis Tyrone Payne v. State of Tennessee green
tenn · 2016
1 sentence

2018In Payne, the petitioner was sentenced to death in 1988 for two murders he committed in 1987. 493 S.W.3d at 480-81 .

12018–2018

Statutes the citing opinions construe

TN § Tenn. Code Ann. § 40-30-102 (30) TN § Tenn. Code Ann. § 40-26-105 (26) TN § Tenn. Code Ann. § 40-30-202 (19) TN § Tenn. Code Ann. § 27-7-103 (17) TN § Tenn. Code Ann. § 40-30-206 (7) TN § Tenn. Code Ann. § 39-13-203 (6) TN § Tenn. Code Ann. § 39-13-204 (4) TN § Tenn. Code Ann. § 40-30-201 (3) TN § Tenn. Code Ann. § 40-30-301 (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

TN 65 (1995–2021) TX 3 (2004–2016)

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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