John Paul Seals vs State of Tennessee

The petitioner, John Paul Seals, entered a guilty plea to first degree murder on December 12, 1988. The state had originally sought the death penalty. The trial court imposed a life sentence. Six years later, the petitioner filed a petition for writ of habeas corpus or, in the alternative, post-conviction relief. The trial court, which treated the petition as one for post-conviction relief, dismissed based upon the statute of limitations. This court affirmed on direct appeal. John Paul Seals v. State, No. 03C01-9409-CR-00319 (Tenn. Crim. App., at Knoxville, Feb. 22, 1995), perm. app. denied, (Tenn. 1995). On January 7, 1998, the petitioner filed this claim for post-conviction relief alleging several constitutional violations. The petitioner argued that the statute of limitations should not apply because he had been mentally incompetent since before the commission of the offense. The petitioner also contended that none of the grounds had been waived or previously determined because the first petition had been filed by someone other than himself. The trial court summarily dismissed the petition at the preliminary stage. See Tenn. Code Ann. § 40-30-206(a), (f). In John Paul Seals v. State, No. 03C01-9802-CC-00050 (Tenn. Crim. App., at Knoxville, Jan. 6, 1999), this court reversed and remanded the cause to the trial court to allow the petitioner to present evidence on the issue of his mental capacity as it related to the statute of limitations: If the petitioner carries his burden of proving facts which require tolling the statute of limitations due to mental incompetence, then the trial court shall proceed to the merits of the constitutional issues presented in the petition. On the other hand, if the petitioner does not carry his burden of proving mental incompetence as regards the statute of limitations, the trial court shall dismiss the petition as untimely. Id., slip op. at 8.