Tolbert v. Toole

Summary

The Court held that the habeas court improperly applied procedural default to Tolbert's claim that his pretrial notice of appeal deprived the trial court of jurisdiction. Because the record showed that Tolbert was represented by counsel when he filed the pro se notice, the notice was unauthorized and ineffective, so it did not suspend the trial court's jurisdiction. The Court therefore affirmed the denial of habeas relief under the right-for-any-reason doctrine.