State v. Brown
Annotate this CaseAdrian Brown filed a pro se motion under Tenn. R. Crim. P. 36.1 seeking correction of allegedly illegal sentences imposed after he pleaded guilty to several crimes. The State responded that Brown’s Rule 36.1 motion should be dismissed because Brown’s sentences had expired. The trial court dismissed the motion without explanation. The Court of Criminal Appeals affirmed, holding that the expiration of Brown’s sentences rendered his Rule 36.1 motion moot. The Supreme Court affirmed, holding (1) Rule 36.1 does not authorize the correction of expired illegal sentences; and (2) the allegation that the trial court failed to award pretrial jail credits was not sufficient to state a colorable claim for relief from an illegal sentence under Rule 36.1. However, because Brown established a clerical error in the judgments on one of his convictions under Rule 36, the matter is remanded to the trial court for correction of the clerical error.
Court Description: Authoring Judge: Justice Cornelia A. Clark
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