Ricky Lee Oldham v. Tennessee Department of Correction

This appeal involves a dispute between an inmate and the Tennessee Department of Correction (“Department”) regarding deductions from the inmate’s trust account to pay the court costs stemming from his criminal conviction. After his inmate grievance proved unsuccessful, the inmate filed a petition for a declaratory order in the Chancery Court for Davidson County seeking a declaration that the Department could not deduct funds from his inmate trust account without a court order. The trial court dismissed the inmate’s petition because it did not state that the inmate had previously sought a declaratory order from the Department. The inmate asserts on this appeal that he should be excused from this requirement because he is undertaking to represent himself and because his grievance was tantamount to a petition for a declaratory order. We affirm the dismissal of the inmate’s complaint in accordance with Tenn. Ct. App. R. 10(b).1