The opinion
04/09/2026
IN THE COURT OF CRIMINAL APPEALS OF TENNESSEE
AT KNOXVILLE
Assigned on Briefs March 25, 2026
CHARLES LANE v. STATE OF TENNESSEE
Appeal from the Circuit Court for Sevier County
Nos. CR4263, CR4247 Jeffrey D. Rader, Judge
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No. E2025-00857-CCA-R3-HC
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The petitioner, Charles Lane, appeals the denial of his petition for writ of habeas corpus by
the Sevier County Circuit Court, arguing the habeas court erred in dismissing the petition.
The petitioner asserts that his pretrial jail credits were not applied properly and that his
request for transcripts was erroneously denied. Following our review, we affirm the habeas
court’s dismissal of the petition as the petitioner has failed to show he is entitled to relief.
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 TIMOTHY L. EASTER and
TOM GREENHOLTZ, JJ., joined.
Rebecca Lee, District Public Defender; Shannon J. Holt, Assistant Public Defender, for the
appellant, Charles Lane.
Jonathan Skrmetti, Attorney General and Reporter; Caroline Weldon, Assistant Attorney
General; Jimmy Dunn, District Attorney General; and Charles L. Murphy, Assistant
District Attorney General, for the appellee, State of Tennessee.
OPINION
Facts and Procedural History
In 1989, the petitioner pled guilty to first-degree murder and aggravated sexual
battery, for which he received an effective sentence of life with the possibility of parole
plus thirty-five years. Less than two weeks after the imposition of his sentence, the
petitioner requested that his pleas be withdrawn, which the trial court denied. The
petitioner appealed, and this Court affirmed the trial court’s denial of the petitioner’s
motion to withdraw his guilty pleas. State v. Lane, C.C.A. No. 111, 1990 WL 192701, at
*1 (Tenn. Crim. App. Dec. 5, 1990), perm. app. denied (Tenn. Feb. 25, 1991).
On February 6, 2023, the petitioner filed a motion to correct a clerical error, arguing
that pretrial jail credits were not applied to his aggravated sexual battery sentence and that
behavioral jail credits were not applied to his first-degree murder sentence. On August 7,
2023, the petitioner filed a motion to obtain records, stating that he is entitled to the
transcripts from his preliminary, guilty plea, and sentencing hearings. On January 24,
2024, the petitioner filed a motion to dismiss, citing the failure to provide him with the
requested transcripts. On October 30, 2024, the petitioner filed a petition for writ of habeas
corpus, arguing that he was wrongly sentenced under the 1989 Sentencing Act and that his
indictment was defective because it failed to cite the correct statutory provision.
Following the appointment of counsel, a hearing was held on April 21, 2025. The
State argued that, because the petitioner’s sentences were ordered to be served
consecutively, his pretrial jail credits were awarded on the first-degree murder sentence
and would not be applied to the aggravated sexual battery sentence. Defense counsel
agreed the petitioner could not “double dip” the jail credits, and the probation officer
confirmed that the petitioner’s first-degree murder sentence showed 270 days of pretrial
jail credit and 72 behavioral credits. Upon hearing from the parties and the probation
officer, the habeas court noted, “Well, that will be it.” Regarding the petitioner’s motion
for transcripts, the State argued that the petitioner received the requested transcripts during
his direct appeal and that he has failed to establish that he is entitled to another copy.
Additionally, defense counsel informed the petitioner that the failure to provide the
transcripts would not result in the dismissal of his case.
After its review, the habeas court issued an order denying the petition for writ of
habeas corpus. This timely appeal followed.
Analysis
On appeal, the petitioner contends the habeas court erred in dismissing his petition,
arguing that he was not granted pretrial jail credits for which he is entitled and that his
request for transcripts was erroneously denied. The State contends the petitioner’s claims
are meritless. Upon our review of the record, we affirm the decision of the habeas court.
Habeas corpus relief is limited in scope and may only be invoked where the
judgment is void or the petitioner’s term of imprisonment has expired. Faulkner v. State,
226 S.W.3d 358, 361 (Tenn. 2007); State v. Ritchie, 20 S.W.3d 624, 629 (Tenn. 2000);
State v. Davenport, 980 S.W.2d 407, 409 (Tenn. Crim. App. 1998). A void, rather than a
voidable, judgment is “one that is facially invalid because the court did not have the
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statutory authority to render such judgment.” Summers v. State, 212 S.W.3d 251, 256
(Tenn. 2007) (citing Dykes v. Compton, 978 S.W.2d 528, 529 (Tenn. 1998)).
A petitioner must establish a void judgment or illegal confinement by a
preponderance of the evidence. Wyatt v. State, 24 S.W.3d 319, 322 (Tenn. 2000).
However, when a “habeas corpus petition fails to establish that a judgment is void, a trial
court may dismiss the petition without a hearing.” Summers, 212 S.W.3d at 260 (citing
Hogan v. Mills, 168 S.W.3d 753, 755 (Tenn. 2005)). Whether the petitioner is entitled to
habeas corpus relief is a question of law. Id. at 255; Hart v. State, 21 S.W.3d 901, 903
(Tenn. 2000). As such, this Court reviews the habeas court’s findings de novo with no
presumption of correctness. Id.
A. Jail Credits
The petitioner first argues his “lack of proper jail credits on his consecutive
sentencing is illegal because it deprives him of the ability to make parole due to his release
eligibility date being improperly calculated.” Our supreme court has stated that a trial
court’s failure to award pretrial jail credit does not render a sentence illegal. Anderson v.
Washburn, No. M2018-00661-SC-R11-HC, 2019 WL 3071311, at *1 (Tenn. June 27,
2019) (Order) (citing State v. Brown, 479 S.W.3d 200, 213 (Tenn. 2015)). Accordingly,
such a claim “is not cognizable in the context of a petition for habeas corpus relief.” Id.
The petitioner is not entitled to relief on this issue.
B. Transcript Request
The petitioner’s next claim also fails to establish that his judgments are void. The
petitioner argues that his request for transcripts was denied, preventing him from
substantiating his claim that his guilty pleas were not knowingly and willingly entered.
Here, the petitioner filed a motion requesting the transcripts from his guilty plea and
sentencing hearings. As the habeas court noted at the evidentiary hearing, this Court
reviewed the transcripts on direct appeal, “fully examined” the petitioner’s guilty pleas,
and determined that they were knowingly and voluntarily entered. See Lane, 1990 WL
192701 (Tenn. Crim. App. Dec. 5, 1990). The transcripts were provided to the petitioner
at the time of his direct appeal in 1990. The fact that the petitioner cannot now obtain
additional copies of the transcripts does not render the judgments void or the sentences
illegal. Accordingly, the habeas court properly dismissed the petition, and the petitioner is
not entitled to relief.
Conclusion
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Because the petition fails to establish a void judgment or expired sentence, we
affirm the judgment of the habeas corpus court.
S/ J. ROSS DYER _
J. ROSS DYER, JUDGE
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