Ronald Paul v. State of Tennessee

The Appellant, Ronald Paul, appeals the dismissal of his pro se petition for post-conviction relief by the Robertson County Circuit Court. Paul, a correctional inmate, timely delivered his petition to the proper prison authorities; however, he inadvertently addressed the envelope containing his petition to the wrong city. The petition was returned to Paul, who, on the same day, corrected his mistake and re-delivered to prison authorities for mailing. These events occurred one day after the one year period for filing had expired. On appeal, Paul argues that the trial court erred in finding his post-conviction petition timed-barred. After review, we hold that Paul's petition was deemed "filed" for purposes of Supreme Court Rule 28 when it was first delivered to prison authorities and, as such, was timely.