State of Tennessee v. James D. Wooden

We granted this appeal to determine whether a party filing a motion under Tennessee Rule of Criminal Procedure 36.1 (“Rule 36.1”) states a colorable claim for relief for correction of an illegal sentence by alleging that the trial court increased his sentence above the statutory presumptive minimum sentence but failed to find enhancement factors justifying the increase. Answering this question requires us to determine the meaning of two terms used in Rule 36.1—“colorable claim” and “illegal sentence.” We hold that the definition of “colorable claim” in Rule 28, section 2(H) of the Rules of the Tennessee Supreme Court applies to the term “colorable claim” in Rule 36.1. Additionally, we conclude that the definition of “illegal sentence” in Rule 36.1 is coextensive with, and actually mirrors, the definition this Court has applied to the term for purposes of habeas corpus proceedings. Compare Tenn. R. Crim. P. 36.1(a), with Cantrell v. Easterling, 346 S.W.3d 445, 452 (Tenn. 2011). Taking the allegations of the Rule 36.1 motion in this case as true and viewing them in the light most favorable to the moving party, we conclude that the moving party has failed to allege a colorable claim for correction of an illegal sentence. Accordingly, the judgment of the Court of Criminal Appeals affirming the trial court’s denial of the Rule 36.1 motion is affirmed.