Stewart v. Schofield
Annotate this CaseAt issue in this appeal was the procedure an inmate must follow to dispute the determination of parole eligibility when the inmate is serving consecutive determinate sentences imposed pursuant to the Criminal Sentencing Reform Act. Under the Uniform Administrative Procedures Act (UAPA), which governs an inmate's challenge to the Tennessee Department of Correction's (TDOC) calculation of a release eligibility date, an inmate must request a declaratory order from the TDOC before filing a declaratory action in court. Petitioner petitioned for a writ of certiorari naming the Board of Probation and Parole and TDOC. The trial court dismissed the petition. The Supreme Court affirmed the trial court, holding (1) because Petitioner failed to seek a declaratory order from TDOC, the trial court properly dismissed his petition naming TDOC and its officials; and (2) the UAPA does not govern an inmate's challenge to a decision of the Board concerning parole, and therefore, the trial court properly granted the Board's and its officials' motions to dismiss because the allegations of the petition failed to state a claim upon which relief could be granted.
Court Description: Authoring Judge: Chief Justice Cornelia A. Clark
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