The opinion
12/29/2025
IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE
AT NASHVILLE
Assigned on Briefs December 9, 2025
MICHAEL EUGENE ST. CLAIR v. STATE OF TENNESSEE ET AL.
Appeal from the Circuit Court for Williamson County
No. 24-CV-527 Deanna B. Johnson, Judge
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No. M2025-00482-CCA-R3-HC
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The petitioner, Michael Eugene St. Clair, appeals the denial of his petition for writ of
habeas corpus by the Circuit Court for Williamson County, arguing the habeas court erred
in dismissing his petition due to improper venue and failure to include the necessary
transcript. Upon our review of the record and the parties’ briefs, we affirm the judgment
of the habeas court.
Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Circuit Court Affirmed
J. ROSS DYER, J., delivered the opinion of the court, in which ROBERT L. HOLLOWAY, JR.,
and ROBERT H. MONTGOMERY, JR., JJ., joined.
Brennan M. Wingerter, Assistant Public Defender – Appellate Division (on appeal); Steve
Garner, Assistant District Public Defender (in the habeas court), for the appellant, Michael
Eugene St. Clair.
Jonathan Skrmetti, Attorney General and Reporter; Ronald L. Coleman, Senior Assistant
Attorney General (on appeal), and Brooke A. Huppenthal, Assistant Attorney General (in
the habeas court); and Stacey Edmondson, District Attorney General, for the appellee, State
of Tennessee.
OPINION
Factual and Procedural History
On December 11, 2002, petitioner entered a guilty plea to one count of rape in
Davidson County. Pursuant to the plea agreement, the petitioner received an eight-year
sentence to be served on probation. Both the petitioner’s plea of guilty paperwork and the
special conditions section of his judgment specifically included “sex offender treatment”
and “sex offender registry” as required. However, neither form indicated that the condition
of community supervision for life, mandated by Tennessee Code Annotated section 39-13-
524, was required.
In both June 2003, the petitioner violated the terms of his probation and was ordered
to serve 90 days in confinement before being returned to probation. In October 2004, the
petitioner again violated his probation. After this violation, the petitioner’s probation was
revoked, and he was ordered to serve his entire sentence in confinement. After each
violation, the trial court entered an “Amended Judgment” reflecting the violation; however,
neither amended judgment reflected community supervision for life.
In March 2010, the Tennessee Department of Correction (TDOC) informed the
Davidson County District Attorney General by letter of the absence of supervision for life
as a condition on the petitioner’s judgment(s) and requested clarification. On May 24,
2010, TDOC issued a Release Notification notifying several parties, including the
Davidson County District Attorney General, that the petitioner’s sentence was to expire on
June 4, 2010.
On June 4, 2010, the petitioner was released from TDOC custody. Prior to release,
the petitioner completed the required sex offender registry, which specified that the
petitioner had “no supervised release.”
On August 16, 2010, the trial court entered a “Corrected Judgment” and included
community supervision for life as a special condition. The petitioner was notified of the
Corrected Judgment on October 27, 2010, and he signed a Community Supervision
Certificate acknowledging that he had received a sentence of supervision for life pursuant
to Tennessee Code Annotated section 39-13-524.
On September 20, 2024, the petitioner, then a resident of Sumner County, filed a
petition for writ of habeas corpus in Williamson County through appointed counsel in an
unrelated matter out of Williamson County. The State filed a motion to dismiss on the
grounds of improper venue and that the petitioner had failed to include the necessary
transcript from his guilty plea hearing.
On March 6, 2025, the habeas court granted the State’s motion to dismiss, finding
Williamson County was not the proper venue. Additionally, the habeas court determined
summary dismissal was appropriate due to the petitioner’s failure to include a copy of the
transcript of his guilty plea. This timely appeal followed.
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Analysis
On appeal, the petitioner asserts that the habeas court erred in dismissing the petition
because (1) venue was proper in Williamson County and (2) sufficient evidence was
provided in the petition to prove supervision for life was not included in the original
sentence. The State responds that the habeas court properly dismissed the petitioner’s writ
of habeas corpus. We agree with the State.
Article I, section 15 of the Tennessee Constitution guarantees the right for prisoners
to seek habeas corpus relief. In Tennessee, “[a]ny person imprisoned or restrained of his
liberty, under any pretense whatsoever . . . may prosecute a writ of habeas corpus, to inquire
into the cause of such imprisonment and restraint.” Tenn. Code Ann. § 29-21-101.
However, the “grounds upon which habeas corpus relief may be granted are very narrow.”
Taylor v. State, 995 S.W.2d 78, 83 (Tenn. 1999). Tennessee Code Annotated section 29-
21-105 requires a petition for writ of habeas corpus “be made to the court or judge most
convenient in point of distance to the applicant, unless a sufficient reason be given in the
petition for not applying to such court or judge.” Our supreme court has construed the
venue requirement to mean that “a petitioner must file the application with the court
geographically nearest to him – generally within the county of confinement – unless the
petition states a sufficient reason for filing elsewhere. Hessmer v. State, No. M2024-
01563-CCA-R3-HC, 2025 WL 1894830, *3 (Tenn. Crim App. 2025) (citing State ex rel.
Leach v. Avery, 387 S.W.2d 346, 347 (Tenn. 1964)). We have recognized an exception to
the geographic requirement allowing for a petitioner to file a petition for writ of habeas
corpus in the convicting court when a petitioner is challenging an illegal or expired
sentence, because that court “possesses relevant records and retains the authority to correct
an illegal sentence at anytime.” Davis v. State, 261 S.W.3d 16, 22 (Tenn. Crim. App.
2008).
Habeas corpus procedural requirements “are mandatory and must be followed
scrupulously.” Archer v. State, 851 S.W.2d 157, 165 (Tenn. 1993) (citing Bateman v.
Smith, 194 S.W.2d 336, 337 (Tenn. 1946)). Specifically, the “statutory venue rule is
mandatory.” Hessmer, 2025 WL 1894830, *3. “A trial court may choose to summarily
dismiss a petition for failing to comply with the statutory procedural requirements.”
Summers v. State, 212 S.W.3d 251, 260 (Tenn. 2007).
In this case, it is uncontested that the petitioner was a resident of Sumner County
when his petition was filed. Therefore, Sumner County was the court geographically
nearest to him and was the statutorily proper venue for filing a habeas corpus petition.
Under the “convicting court” exception, the Davidson County Criminal Court would have
also satisfied the venue requirement. See Davis, 261 S.W.2d at 20. However, the petitioner
filed his petition in Williamson County. Therefore, his petition must have provided a
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sufficient reason for failing to file in either of the proper venues. Failure to do so subjected
his petition to dismissal. See id.
In his petition, the petitioner argued that Williamson County should be declared a
proper venue because his attorney of record is a public defender appointed to Williamson
County. The habeas court found that “[t]he fact that Petitioner’s counsel believes he cannot
represent Petitioner in Sumner County because is he a public defender in Williamson
County is not sufficient reason for Petitioner to file his Petition in this county rather than
in Sumner County.” Whether habeas corpus relief should be granted is a question of law,
so our review is de novo with no presumption of correctness afforded the habeas court’s
findings and conclusions. Summers, 212 S.W.3d at 255.
At issue, is whether the petitioner in his application presented a sufficient reason for
filing his petition in Williamson County. The crux of the petitioner’s argument is that the
application was filed in Williamson County because petitioner’s counsel believed he could
not file in Sumner County. However, as the habeas court noted in its order, the petitioner
does not have a right to counsel in a habeas corpus proceeding. See id. at 261.
“Appointment of counsel in a state’s habeas corpus proceeding is within the trial court’s
discretion.” Id. at 260. Tennessee Code Annotated section 40-14-204 provides that the
court will appoint counsel “if necessary.” Therefore, a particular counsel’s county of
appointment cannot be a sufficient reason to convey venue in a proceeding that mandates
scrupulous adherence to rules of procedure. Additionally, we note that “appointed
counsel” in the instant matter was not appointed to represent the petitioner in his habeas
matter; rather, counsel was appointed to represent the petitioner in an unrelated matter out
of Williamson County. Accordingly, we conclude that the habeas court did not err in
dismissing the petition.
In addition to dismissing the petition for the lack of proper venue, the habeas court
also determined the petitioner failed to establish that his judgment was void. More
specifically, the habeas court found the record was unclear as to whether community
supervision for life was initially discussed and imposed as part of the plea colloquy, noting
that the petitioner failed to provide a transcript of the plea hearing. The petitioner argues,
as he did at the trial level, that the transcript is no longer available but insists we can rely
on the court reporter’s log “which indicates a brief description of what occurred” at the
petitioner’s plea hearing. Initially, the State notes that pursuant to Tennessee Rule of
Criminal Procedure 36, the trial court was authorized to correct a clerical error “at any
time.” The State then submits the habeas court “reasonably found that ‘without a transcript
from the guilty plea hearing’ it could not determine whether the petitioner ‘was informed
the [community supervision] requirement was part of his guilty plea.’” We agree with the
State.
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As noted by the State, Tennessee Rule of Criminal Procedure 36 provides that a trial
court “may at any time correct clerical mistakes in judgments. . . .” In the instant matter,
in August 2010, the original trial court, after receiving notice from the Department of
Correction, entered a “Corrected” judgment reflecting that the petitioner had been
“sentenced to community supervision for life.” Despite having an appeal as of right from
the entry of that corrected judgment, see Tenn. R. Crim. P. 36, the petitioner took no action.
Rather, in October 2010, the petitioner signed a certificate acknowledging that he had been
ordered to community supervision for life and agreeing to comply with the enumerated
conditions. The petitioner did not challenge the lifetime supervision portion of his
judgment until filing the instant petition in September 2024.
Unfortunately for the petitioner, by the time he decided to challenge the legality of
his sentence and the trial court’s entry of a corrected judgment, the recording of his plea
hearing was no longer available. The “petitioner bears the burden of providing an adequate
record for summary review in a habeas corpus petition.” Summers, 212 S.W.3d at 259.
When a petitioner fails to include pertinent documents with his petition, the habeas court
may properly dismiss the petition without the appointment of counsel and without a
hearing. Id. at 261. Though the petitioner did present the habeas court with the court
reporter’s log and notes from the date of the petitioner’s plea hearing, such is not the official
transcript of the hearing and, as noted by the petitioner, only “indicates a brief description
of what occurred”—it is not a complete and accurate transcript of the hearing.
Accordingly, based on the lack of a complete record, the habeas court did not abuse its
discretion in summarily denying the instant petition.
Notwithstanding the petitioner’s failure to file in the proper venue and failure to
provide the habeas court with an adequate record to review his claim, the petitioner would
not be entitled to relief on the merits of his claim. The petitioner claims the habeas court
lacked jurisdiction to correct his judgment once the petitioner was released from custody.
However, both our supreme court and this Court have held to the contrary. See generally
State v. Brown, 479 S.W.3d 200 (Tenn. 2015); Anthony Leslie v. State, No. M2018-00856-
CCA-R3-HC, 2019 WL 3814623 (Tenn. Crim. App. Aug. 14, 2019), no perm. app. filed.
Community supervision for life is “a sentence” in addition to any term of confinement. See
Tenn. Code Ann. § 39-13-524(a) (“In addition to the punishment authorized by the specific
statute prohibiting the conduct, a person shall receive a sentence of community supervision
for life . . . .”) (Emphasis added). “The sentence of community supervision for life shall
commence immediately upon the expiration of the term of imprisonment imposed upon the
person by the court or upon the person’s release from regular parole supervision, whichever
first occurs.” Id. § 39-13-524(c). The plain language of the statute reflects that the sentence
of community supervision for life begins, in relevant part, upon the expiration of the term
of confinement. Carr v. State, No. M2017-01389-CCA-R3-PC, 2019 WL 6220966, at *7
(Tenn. Crim. App. Nov. 21, 2019) (Montgomery, J., concurring in part; dissenting in part).
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The petitioner’s original sentence included an eight-year sentence to serve in the
Tennessee Department of Correction, suspended to probation, and lifetime community
supervision for life, regardless of whether the parties and the trial court were aware of the
sentence at the guilty plea hearing. The sentence of lifetime supervision was mandated by
statute, and the failure to note it on the original judgments of conviction resulted in void
judgments. Although the petitioner’s service requirement in the Tennessee Department of
Correction had been completed at the time the corrected judgments were entered, his
lifetime supervision sentence had not expired. Id.
For purposes of habeas corpus as a mechanism to correct an illegal sentence, it is
irrelevant whether the petitioner knew about the statutorily mandated sentence of lifetime
supervision. Rather, the petitioner’s knowledge of lifetime supervision is a question of
whether the petitioner entered knowing and voluntary guilty pleas and whether he received
the ineffective assistance of counsel, which are matters to be addressed in a petition for
post-conviction relief. Id. (citing Calvert v. State, 342 S.W.3d 477 (Tenn. 2011); State v.
Nagele, 353 S.W.3d 112 (Tenn. 2011)). The petitioner’s full sentences had not expired at
the time the corrected judgments of conviction were entered, and, as a result, the trial court
had the authority to correct the illegal sentences contained in the judgments of conviction.
Id.
Conclusion
Based on the foregoing, we affirm the habeas court’s dismissal of the petition for
writ of habeas corpus.
S/ J. ROSS DYER _
J. ROSS DYER, JUDGE
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